CODE OF ETHICS

PURPOSE: Restore Fx is committed to maintaining the highest ethical standards. It is our responsibility to ensure these standards with our patients, stakeholders, vendors, suppliers, and the communities where we live and work, as well as to each other. Trust is at the heart of these commitments and trust is built on honesty and dependability regarding ethical conduct. POLICY: Restore Fx complies with the legal and regulatory requirements, which include rights of the persons served, confidentiality requirements, reporting requirements, contractual agreements, licensing requirements, corporate status, employment practices, mandatory employee testing, privacy of the persons served, debt covenants, and other applicable standards. ubpoenas, search warrant, investigation, or other legal action will be directed to the !dministrator and executive leadership. The "ode of #thics applies to the $anaging %wners, !dministration, &irectors, and all employees of Restore Fx including contractor employees. #ach person is responsible for his or her own behavior and actions and while performing 'ob responsibilities, all personnel is personally responsible for ensuring that all conduct reflects positively on the company. This includes corporate citi(enship activities in which Restore Fx personnel or owners may be engaged. These responsibilities include)

"omplying with all laws and regulations applicable to one*s position "omplying with all company polices $aintaining appropriate ethical behavior as described by Restore Fx +olicies and their own particular discipline code of ethics ,ot assisting others who are attempting to violate any law, policy, regulation, or committing an unethical act

Restore Fx Ethical codes of Conduct

Restore Fx has a responsibility for stewardship and the protection of its assets from misuse so as to perpetuate its mission. Restore Fx is committed to compliance with the laws and governance to which it is sub'ect as well as with Restore Fx policies and procedures. #mployees, contractors and volunteers of Restore Fx have a responsibility to disclose or report any circumstances where Restore Fx*s internal controls, independent review function, auditing function, compliance monitoring function, accounting systems or governance policies have been or may become compromised or threatened. This includes actual knowledge, or a reasonably strong belief, of such an occurrence or possibility. This policy applies to all Restore Fx employees, contractors and volunteers. o Retaliation Polic! Restore Fx will not tolerate retaliation, whether direct or indirect, against any employee, contractor or volunteer who makes a good faith report or who cooperates with an investigation of a complaint. -nder this policy .commonly referred to as a /whistleblower policy01, those who report illegal or improper activity will be protected. $oreover, any employee, contractor or volunteer who engages in such retaliation will be sub'ect to discipline up to and including termination. Education on Ethical Codes Restore Fx attempts to educate all stakeholders on its ethical policies and procedures in the following ways)

+osting the #thics +olicy on its website in both #nglish and panish +roviding a written copy of the #thics +olicy in the +atient %rientation $anual 2aving all employees .to include contract employees1 and owners review and sign a copy of the #thics +olicy upon hiring and3or whenever changes are made to the document. 2aving all owners review the #thics +olicy annually at the $anaging %wners meeting. +roviding copies of our ethics policy when possible if engaged in corporate citi(enship efforts, for example by noting that it is posted on our website and providing the -R4 for the website. !dvising any patient advocates encountered in the treatment of a Restore Fx patient as to our #thics +olicy and providing them with a written or electronic copy at their request. +roviding education to such advocates in situations where we feel that their behavior may be in conflict with our #thics +olicy.

Process for Re"ortin#

!ny personnel or owner who witnesses or suspects an ethical violation, fraud, waste, theft, abuse or other wrong doing promptly re"orts and provides related information to the !dministrator. If an individual is uncomfortable with reporting to the !dministrator, s3he reports to the +rogram &irector. The +rogram &irector forwards any such report immediately to the !dministrator and3or the $anaging %wners. The !dministrator treats all reports in confidence and protects the identity of the reporter, unless it is incompatible with a fair investigation. 2owever, information that involves a threat to life and property, illegal activities, or legal action against the company may require action that does not allow for complete anonymity. 5iolations of the +olicy are grounds for discharge or other disciplinary action, adapted to the circumstances of the particular violation and having as a primary ob'ective furtherance of the Restore Fx*s interest in preventing violations and making clear that violations are neither tolerated nor condoned. &isciplinary action will be taken, not only against individuals who authori(e or participate directly in a violation of the +olicy, but also against) +rovided the allegations are made without malice and in the public interest, ensures no retaliation against the reporter .see ,o Retaliation +olicy above1. In$esti#ates all reports within 67 days of receipt. Docu%ents all investigations in a confidential report. The report outlines any action.s1 to be taken, which may include disciplinary action up to and including dismissal8 changes to policy or practice8 reporting to the !uditors8 or reporting to the +olice or other regulatory agencies such as licensing boards and3or accrediting organi(ations such as "!RF. The !dministrator undertakes and oversees any actions resulting from an investigation report. It is important that any lessons be learned and shared throughout the agency.

.61 any employee who may have deliberately failed to report a violation of the +olicy8 .91 any employee who may have deliberately withheld relevant and material information concerning a violation of this +olicy and .:1 the violator*s managerial superiors, to the extent that the circumstances of the violation reflect inadequate leadership and lack of diligence.

In the event that the +olice become involved, the $anaging %wners represents the agency. The !dministrator ensures that the results of the investigation are included in the !nnual Report. If they are of a serious nature or may have legal or

public implications for the agency, the !dministrator reports them promptly to the $anaging %wners. Reporting to "!RF is also required for serious allegations and investigations. 1. Patients: Restore Fx believes its first responsibility is to the patients who receive our services. ;e will deal with patients with openness and honesty, and they will reali(e they can not only depend on receiving quality services, but also on our personal word and character as individuals and as an organi(ation. 2. Stakeholders) Restore Fx will provide quality services at a fair price and ensure that the needs and interests of stakeholders are represented. ;e will maintain ongoing communications with stakeholders to gain information necessary to make certain needs are met. 3. Vendors and Suppliers) Restore Fx will ensure fairness in interactions with vendors and suppliers with our interest and needs determining what products and services our purchased. %ur decisions are based on factors such as quality, service, costs, and reliability. 4. Community) <eyond the day to day quality services that the community expects, Restore Fx will assist in the communities civic and charitable activities as appropriate. 5. Marketing !ll employees of Restore Fx will follow the !merican $arketing !ssociation guidelines to ensure ethical marketing when representing Restore Fx. $arketing personnel must also abide by the Restore Fx #thics +olicy and where one policy is in conflict with another the Restore Fx #thics +olicy shall prevail. "opies of the !merican $arketing !ssociation #thics +olicy document are available from the !dministrator or on the server under 2uman Resources in the #thics for $arketing folder. 6. !ual "pportunity: !t Restore Fx, our policies, practices, and procedures are developed to ensure that we are treated fairly and with respect, and that we treat others with the same respect. Restore Fx does not discriminate on the basis of race, color, religion, sex, sexual orientation, age, origin, disability or veteran status. ;e value the unique contribution that each person brings to the workforce and consider our

different perspectives an important part of our ability to serve our patients. <y listening to each other*s ideas and views, we are more able to make use of individual contributions and more able to understand fully the experiences of our patients. ubsequently, we are more able to understand the way they see things and can then anticipate their needs and respond to them more effectively. The richness of talents is reflected in all parts of the organi(ation, including employment practices, marketing strategies and service to patients. #. $ealth and Sa%ety: Restore Fx is responsible for maintaining a safe and healthy work environment. "hances of patients, staff or visitors being in'ured is minimi(ed by following that law, site regulations and common=sense practices. 2a(ardous situations are immediately reported to the appropriate party and all staff is familiar with emergency procedures, important telephone numbers and office locations. In addition, staff has the advantage of company sponsored in= services and training concerning ha(ardous situations, substances, and protective measures. Restore Fx does not tolerate any abusive language, physical violence, or threat of physical violence. Firearms and other weapons are strictly forbidden and are not allowed on company property, parking lots, or vehicles. &. n'ironment: Restore Fx works to devote resources and energy to maintaining environmental compliance and concerns > making sure ha(ardous waste, material, etc. are disposed of safely and according to law. taff will report environmental accidents or suspected violations of environmental laws and regulations to the proper Restore Fx staff member or environmental protection division as appropriate. 2arassment Free ;orkplace) 2arassment may take many forms, from overt advances to demeaning comments, 'okes, language, and gestures. #ven if it is not intended in a harassing manner, such behavior may be perceived as harassment and it is important to be sensitive to how others could see such behavior. ;henever words, behaviors, or actions of the staff create an intimidating, hostile, or offensive environment, it may be considered harassment. !lthough it may not be directly involve a direct threat, it can be destructive to a positive working environment. In the event an unwanted sexual advance is made and reported, your 'ob, evaluation, pay or work assignments are not threatened because a sexual advance was re'ected.

(. Con%li)t o% *nterest: Restore Fx and its staff strive to avoid any situation that holds potential to act in a manner that is not in the best interest of the organi(ation. election of vendor or suppliers, as well as purchasing decisions must always be made on the basis of evaluating and comparing price, quality, performance and suitability. &ecisions are not influenced by any other factor, such as personal relationships, gifts, hospitality or anything else of direct or indirect value. ?enerally, it is usual to accept unsolicited gifts from suppliers as long as it is customary for our 'ob or position, although it never appropriate to request a gift. It is never allowable to accept cash or cash equivalent including checks, money orders, or vouchers. It is especially important to avoid even the appearance of conflict of interests. !s a general rule, it is a good idea not to accept anything beyond an occasional meal or gift of a nominal value. Patients: ;hen seeking business from our customers, Restore Fx will provide quality services at fair prices. !ny business that is won by providing unusual gifts for hospitality is inappropriate. It is appropriate however, to sponsor events or activities for patients or potential customers that enable the building of relationships. ;hen planning such events, awareness and sensitivity to our customer*s practices and standards regarding conflict of interest is addressed. Personal +ains: Restore Fx staff is also careful to avoid outside conflicts of interest situations outside of our work. If is inappropriate for staff or their family members to receive improper benefits as a result of his or her position in the company. In addition, Restore Fx information and resources are not to be used for personal gain, whether financial, or otherwise. "ontacts or positions with the company should never be used to advance personal, private business or financial interest, whether or not is at the company*s expense. This includes using contacts made through work .such as relationships with co=workers1 for personal fund raising. #xceptions may be made at the discretion of the !dministrator if a particular fund raising activity is associated with the corporate citi(enship of Restore Fx. ,air Competition: !ntitrust laws are those laws and regulations that are meant to ensure that the marketplace remains competitive. "ompliance with these laws are important to Restore Fx and all employees have a responsibility to comply.

"ustomers who are also competitors are treated fairly and not disadvantaged. ;e will not discriminate between the level of service provided and the service provided to competition. <e truthful and accurate when describing the quality, features, or availability of services to our patients. <e similarly careful in describing a competitor*s products or services. It is never appropriate to critici(e a competitor to a patient or interfere with any contact between a patient and a competitor. 1-. Patient *n%ormation: !s a result of our interaction with patients, Restore Fx staff knows a lot about them and their situation and the trust they place in us is highly valuable. !ny inappropriate use of confidential patient information weakens that level of trust and our relationship with them. It is a serious violation of our company standards, as well as the law, to use any information for anything other than Restore Fx business. 11. Pri'a)y o% Communi)ations +rivacy of communications is basic to our business, both legally and because our patients trust our integrity. They have a right to expect us to abide by these standards and not to otherwise listen to their conversations or monitor their movements. $aintaining this trust is a fundamental part of the way we do business and should guide the decisions we make about the information we have access to. !ny request from anyone, including a law enforcement or governmental agency, that involves privacy of communications should be referred immediately to the !dministrator and the $anaging %wners. 12. *ntelle)tual Property Restore Fx*s creativity and innovative ideas make significant contributions to its continued success in the marketplace. !ll personnel are encouraged to us their skills and knowledge to develop new and improved services and to discover improved ways to work. The company*s accomplishment depends on protecting our intellectual property. Therefore, it is important to not leave proprietary information lying visibly on our desks or in other places where it could be easily found by unauthori(ed individuals. ;e shouldn*t discuss confidential information in public places, where it could be overheard. ;e also need to follow required procedures for safeguarding and disposing of proprietary information, rather than throwing it away in an ordinary garbage can. uch documents should be placed in a locked shredding bin to be disposed of by the company*s shredding service. +articipation in Trade !ssociations and %ther $eetings with "ompetitors ,o employee shall attend or remain present)

.61 at any surreptitious meeting of competitors8 .91 at any meeting where there is a discussion by competitors of any sub'ect which a Restore Fx employee is precluded from discussing by the paragraph above on &iscussions and #xchange of Information with "ompetitors8 or .:1 at any informal meeting of competitor members of a trade association held for the purpose of discussing business matters without observing the formal procedural requirements established by such trade association for its business meetings. 13. .aste ,raud/ 0he%t/ 12use "ther .rong 3oing In order to safeguard the ethical, organi(ational and financial well=being and reputation of Restore Fx the organi(ation has a duty to conduct its affairs in a professional, ethical, responsible and transparent way and to follow applicable laws, regulations, contract requirements and standards. ;e operate in good faith and take all reasonable steps to prevent, detect, investigate and address any fraud, waste, theft, abuse or other wrongdoing. In order to ensure the above Restore Fx employees, owners, volunteers and contractors will abide by the following) 1. +ersonnel work together to create an organi(ational culture and environment that is risk=averse and discourages and "re$ents such actions)

+ersonnel are responsible for knowing the signs of potential fraud, waste, theft, abuse or other wrongdoing. These include prime documents being lost and replaced by photocopies8 unexplained sudden change in lifestyles8 new personnel resigning quickly8 and suppliers3contractors3customers insisting on dealing with a particular staff person. The !dministrator is responsible for managing risks through the Risk $anagement +lan. The !dministrator implements, documents, tests, operates and monitors internal controls. The !dministrator ensures adequate training in agency policies.

1. The !dministrator is responsible for the following steps to detect waste, fraud, theft, abuse or other wrongdoing)

Follow audit procedures. #nsure routine checks and monitoring of compliance with policy. Follow=up on any irregularities as soon as identified.

:. !ny personnel who witnesses or suspects fraud, waste, theft, abuse or other wrong doing promptly re"orts and provides related information to the !dministrator. If an individual is uncomfortable with reporting to the !dministrator, s3he reports to the +rogram &irector. The +rogram &irector forwards any such report immediately to the !dministrator and3or the $anaging %wners. 7. The !dministrator and3or $anaging %wners respond in accordance with the /+rocess for Reporting0 section outlined earlier in this policy. 14. .itnessing 3o)uments taff members are prohibited from witnessing legal documents. +articipants requiring such services will be referred to the appropriate legal services. 14. Setting 1ppropriate 4oundaries Boundary violations and boundary crossings in patient care refer to any deviation from traditional, strict, @only in the office,* emotionally distant forms of treatment. They mostly refer to issues of self disclosure, length and place of treatment sessions, physical touch, activities outside the treatment facility, gift exchange, social and other non=therapeutic contact and various forms of dual relationships. 4oundary 'iolations in patient care are harmful to patients and include but are not limited to sexual contact with patients or exploitative business arrangements with patients. Restore Fx prohibits the exchange of money or gratuities with patients and also prohibits the exchange of gifts with significant monetary value .more than A9B1. Restore Fx &ILL OT tolerate boundary violations of any kind. Boundary violations must be reported if they are witnessed or suspected and are grounds for immediate termination. Boundary violations will also necessitate contacting any professional board or licensing agency if the offending party is a licensed professional 4oundary )rossings are different from boundary violations and are not necessarily harmful and can prove to be extremely helpful in the treatment of patients. Boundary crossings may allow for flexibility in the rendering of treatment, provide a sense of genuineness and humanity in patient care and increase trust if appropriate boundaries are maintained. #xamples of boundary crossings that may be therapeutic are driving in a car with a patient who has fear of driving due to an accident8 going for a vigorous walk with a depressed patient8 accompanying a patient to a medical visit that they have severe apprehension about8 giving a non=sexual hug to a patient who has requested such8 sending cards8 exchanging appropriate .not too expensive1 gifts8 lending a book8 attending a wedding or funeral8 or going to see a patient performing in a show. Boundary crossings are not unethical. #thics code of all ma'or psychotherapy professional associations .e.g., !+!, !p!, ,! ;, !"!, ,<""1 do not prohibit boundary crossings, only boundary violations.

15. 4usiness Controls. Restore Fx develops processes that enhance the overall quality of financial reporting and operational effectiveness of the organi(ation. ?ood business controls are in place in order to maintain confidence in the integrity of our financial reports' to establish a foundation for the achievement of business ob'ectives and hel" ensure co%"liance (ith la(s' re#ulations and co%"an! "olicies) These practices are designed to prevent, detect and3or correct process problems and continued effectiveness of the controls is a responsibility of the management team. $anagement continually reviews existing policies and procedures to enhance our ability to provide patients with the services that they require and business controls are a key element of those processes. &irector and level managers are charged with the design of the internal control processes developed to meet those ob'ectives Co%"an! Funds * Pro"ert!: Restore Fx !dministrator, +rogram and $edical &irectors, $anaging %wners and staff are responsible for safeguarding corporate assets and resources to which they are entrusted. uch resources should not be used for personal benefit or disposed of without appropriate approval. "ompany cash, checks, money orders, and credit cards should never be used for personal use. 5ouchers, time sheets, invoices, and benefits claims are used to obtain company funds and property. Inaccurate or incomplete documents can result in an improper, and potentially fraudulent, acquisition of company assets. Re"orts and Periodic Re$ie(s !ny employee who is requested to engage in any activity which is or may be contrary to this +olicy will promptly report such information to the !dministrator, or, if the employee was so directed by the !dministrator, then to assigned "ompany legal counsel. !ny employee who acquires information that gives the employee reason to believe that any other employee is engaged in conduct forbidden by the +olicy will promptly report such information to the !dministrator, if the !dministrator is engaged in such conduct, then to the assigned "ompany legal counsel. DEFI ITIO S: Fraud is a dishonest and deliberate course of action that results in the obtaining of money, property or an advantage to which the recipient would not normally be

entitled. #xamples include not completing a shift, or working fewer hours that you are paid for. Theft is the wrongful taking of someone else*s property without that person*s consent. It encompasses offences such as robbery, theft by deception, and sometimes criminal exchange. Theft also includes the theft of time, whereby staff are on shift to accomplish the goals of Restore Fx, but they are using Restore Fx time for personal activities without the direct consent of the !dministrator. &aste is the expenditure or allocation of resources significantly in excess of need. +,use, as used in this policy, is a kind of waste that entails the exploitation of /loopholes0 to the limits of the law, primarily for personal advantage. &ron#doin# is an illegal or immoral act. #xamples include the above, as well as lying, bullying, and intimidation.