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compliance with the Corporate Compliance Program and the Code of Conduct is a condition of employment. Additionally, employees will be made aware that adherence to the Corporate Compliance Program and the Code of Conduct will be taken into consideration as part of the employee’s annual evaluation. Employees also may be required to participate in other mandatory training sessions in addition to those conducted by the Compliance Officer or his/her designee pursuant to the Corporate Compliance Program, to the extent such employees have specific responsibilities for activities relating to FHCP’s participation as a first tier entity under the Medicare Advantage and Part D Programs. Compliance Plan 3 - 3 Revised December 12, 2018 As applicable, training shall include, but not be limited to, laws related to fraud and abuse, accuracy and completeness of data, anti-dumping, conflicts of interest, business ethics, under/over utilization, and selective marketing and enrollment. For additional information, please refer to FHCP policy LD012 – Anti-Fraud Plan, which is available through the FHCP intranet, Vigilant Policy Center. IX. Role of Managers and Supervisors in Training and Education Managers and supervisors are required to instruct subordinates in Corporate Compliance Program requirements and support their participation in such corporate training programs. Additionally, as noted elsewhere in this Corporate Compliance Plan, failure of managers and supervisors to detect non-compliance with applicable policies, including training and education initiatives, can result in disciplinary action. X. Education Records The Compliance Officer shall be responsible for maintaining records as evidence that all employees have participated in compliance training activities. Examples of education records include attendance logs and test results. At a minimum, attendance logs shall include the session topic, date, instructor, and the name and department of all attendees. This data is also available in the Guide Well Learning system. Test results shall be maintained for each employee and shall include similar information. In the event that an employee fails to meet the minimum 80% standard set forth for the annual test, the Compliance Officer or his/her designee, shall maintain a record of follow-up actions taken to ensure the employee has adequate knowledge of the subject area. Compliance Plan 4 - 1 Revised December 12, 2018 COMMUNICATIONS I. Purpose Strict adherence to the Code of Conduct and Compliance Plan by the organization, its employees, and its Downstream and Related Entities is vital. Supervisors are responsible for ensuring that employees are aware of and adhere to the provisions of the Code of Conduct and Compliance Plan. For clarification or guidance on any point in the Code of Conduct or Compliance Plan, individuals may consult a member of the Compliance Committee or the Compliance Officer. Employees are expected to report any suspected violations of the Code of Conduct or Compliance Plan. Individuals may report such suspected violations to his/her supervisor, the Compliance Officer, or a member of the Compliance Committee. If the employee wishes to protect their identity, the employee may submit his/her report through the Ethics and Concerns Help Line @ 386-615-4080, internal extension 4080. All FHCP Downstream and Related Entities should report suspected non-compliant behavior, either in accordance with their employer’s compliance plan or directly to FHCP’s Compliance Officer or Compliance Committee as described in this section. FHCP understands its obligations to inform employees and First-Tier, Downstream and Related Entities of regulatory and policy changes in a timely manner in order to ensure effective implementation. Such information is shared with individuals in a variety of ways, including staff meetings, interoffice mail, and e-mail. The method of distribution is determined based on urgency and length of content. II. Reporting Suspected Violations or Irregularities Reports of suspected violations or irregularities should contain sufficient information for the Compliance Officer to investigate the concerns raised. No adverse action or retribution of any kind will be taken by FHCP against an individual because he or she, in good faith, reports a suspected violation of this Compliance Plan or the Code of Conduct, as long as the individual was not a participant in the act(s). In an effort to encourage free and open reporting of activities or events that are suspected to be inconsistent with the Code of Conduct and/or Compliance Plan, FHCP has developed numerous mechanisms for reporting such issues. These include: A. Direct Reporting Employees should first attempt to address concerns through his or her supervisor. If an employee is uncomfortable going to their supervisor, the employee can go to the Compliance Officer. If uncomfortable going to the Compliance Officer, the employee can go to a member of the Compliance Committee. If the employee wishes, the report can be made anonymously through the Ethics and Concerns Help Line. Compliance Plan 4 - 2 Revised December 12, 2018 B. Reporting through the Statement of Understanding Employees annually shall have an opportunity to raise concerns through completion of the Statement of Understanding. Upon initial adoption of the Compliance Program and annually thereafter, employees sign statements acknowledging their understanding of the Code of Conduct and Compliance Plan. This Statement of Understanding includes an opportunity to report violations in response to the following question: "At this time, I am not aware of any possible violation of the Code of Conduct or Compliance Plan, except as noted below." The Compliance Officer reviews responses to these statements. C. Reporting through Exit Interviews All employees leaving employment will complete an exit interview with the Human Resources department. Potential issues of non-compliance identified during the interview are referred to the Compliance Department for evaluation and action. III. Other Types of Concerns In addition to the processes in place to address suspected violations of the Code of Conduct or Compliance Plan, FHCP maintains processes for responding to issues with Quality of Care and Employee Relations. A. Quality of Care Concerns If an employee encounters a situation where it is believed that the quality of care being rendered is inappropriate, the employee should immediately report it to the Administrator of Quality Management/Performance Improvement or the Chief Medical Officer In these situations, the well-being of the patient takes precedence over all else. B. Employee Relations Concerns These concerns involve the relationship between an employee and their supervisor, another employee, or the Human Resources Department. Examples of concerns falling into this category include: • A conflict with a supervisor regarding job performance or disciplinary action • A conflict with a coworker • Discrimination, harassment or abusive behavior, hostile workplace situations • Improper denial of benefits or due process relating to a benefit. FHCP’s process by which concerns of this type are addressed can be initiated by making an appointment with the Human Resources Department or reporting