2.701 Corporate Compliance Plan

PHP POLICY:

The facility is committed to managing and operating its programs using the highest business, ethical and moral principles. The Corporate Compliance Program (the “Compliance Plan”) outlines the unwavering tenets that (a) promote compliance with applicable federal and state laws and regulations; (b) ensure compliance through monitoring and disciplinary procedures; and (c) evaluate periodically the effectiveness of the Compliance Plan.

All employees and other agents shall be encouraged to report any and all acts of wrongdoing involving PHP and its operations. To facilitate such reporting, PHP shall institute a mufti-tiered reporting system. First, PHP shall implement a “Corporate Compliance” page on the the PHP website that can receive reports of wrongdoing twenty-four (24) hours per day and seven (7) days per week. All “Corporate Compliance” page reports may be acquired through a third party. The “Corporate Compliance” page operator shall be instructed to inform the Corporate Compliance Officer, the Chairman of the Compliance Committee, and the Vice-Chairman of the Compliance Committee immediately of any reports of wrongdoing. Second, reports of wrongdoing may be made directly to the Deputy Compliance Officer, who shall immediately communicate such report to the compliance hotline.