Atlantis Health Code of Conduct

About this Code

At Atlantis Health, we prioritise corporate integrity, responsible sourcing, environmental sustainability, and the safety and wellbeing of workers in the countries where we operate. As a company operating in a highly regulated industry, strict adherence to all relevant laws, regulations, and codes regarding unlawful or improper payments or benefits is crucial.

Our Code of Conduct (Code) embodies these core principles and establishes minimum standards to safeguard our business, reputation and people.

The purpose of Atlantis Health's Code is to:

• promote honest and ethical conduct, fostering personal accountability among all our people;

• ensure compliance with applicable laws, rules, and regulations, maintaining a culture of legal integrity and responsibility;

• safeguard company assets and information, recognising their importance to our continued success and sustainability; and

• encourage prompt reporting of any illegal or unethical behaviour, enabling swift resolution and mitigation of risks to the company, reputation and people.

By upholding these principles and standards outlined in our Code, Atlantis Health is committed to conducting business ethically responsibly and in a manner that contributes positively to society and the environment.

Compliance with Laws and Regulations and Priority of Standards

We will, in addition to complying with the standards set out in this Code, comply with all applicable laws, regulations and codes of any other countries in which we operate. If there is a conflict between any applicable laws or regulations and the provisions of this Code, Atlantis Health shall meet the most stringent standard.

Who is this Code for?

We expect all employees to know, understand and follow the Code. Failure to do so can result in disciplinary action, up to and including termination of employment.

We also expect our contractors, consultants and suppliers to comply with the principles of the Code when they work with us . Failure of an Atlantis Health contractor, consultant or other service provider to comply with the principles of the Code can result in termination of their relationship with Atlantis Health.

Code of Conduct

You’re expected to be honest, act ethically and demonstrate integrity in all situations. You have a duty to follow this Code and all applicable related policies and procedures, as well as those that are specific to your job. You must also comply with all laws that apply to our business. Most of the time, common sense and good judgment provide excellent guideposts. If you’re unsure about the right thing to do, ask someone on the management team.

Before You Act, Ask Yourself:

• Is this the right thing to do?

• Am I following Atlantis Health’s core principles and values?

• Is it legal?

• Do I have the authority to act?

• Does the action comply with the Code and applicable policies and procedures?

• If this action became public, how would it look in the news media?

• Would I be upset or embarrassed if other people found out about this action?

If your answer to any of these questions raises doubts or questions, talk with your supervisor or anyone in management team. DO NOT PROCEED BEFORE YOU HAVE DONE THIS.

If you’re a supervisor or a manager, you’re responsible for knowing the rules and reviewing the Code with the people who report to you to make sure they’re familiar with its contents and requirements. You’re also responsible for preventing violations of the Code, as well as detecting violations that may occur and reporting them appropriately.

You’re expected to:

• lead with integrity;

• encourage employees to ask questions and expand their knowledge of the rules;

• demonstrate integrity by acting promptly and effectively when necessary; and

• educate employees on compliance policies specific to their job responsibilities.

Equal Opportunities. Atlantis Health is an equal opportunities employer and shall not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement or any employment practice based on race, caste, color, national origin, gender, gender identity, sexual orientation, religion, age, marital or pregnancy status, disability, union membership or political affiliation or any other characteristic other than the employee’s ability to perform the job subject to any accommodations required or permitted by law.

Working Environment. We are committed to a supportive work environment, where our employees have the opportunity to reach their fullest potential. Members of our Atlantis Health team are expected to do their utmost to create a workplace culture that is free of harassment, intimidation, bias and unlawful discrimination. We are committed to ensuring the health and wellbeing of our employees and providing a safe and suitable workplace in compliance with all applicable health and safety laws where we operate.

Slavery, Human Trafficking and Child Labour. We shall comply with all applicable anti-slavery and human trafficking laws, statutes and regulations in any part of our supply chain. This includes, but is not limited to, not supporting or engaging or requiring any forced labour, the use of child labour, bonded labour, indentured labour and prison labour.

Data Protection and Information Security. Atlantis Health shall comply with all data protection laws and requirements when processing any personal data.

Atlantis Health shall have in place appropriate measures to:

• protect the integrity and confidentiality of information (including information belonging to or supplied by clients) held on its systems (which include physical and online or electronic systems); and

• ensure that there is no unauthorised access of the information by third parties.

Environmental Responsibility. We are committed to making continuous improvements in the management of our environmental impact and development of a sustainable business.

Bribery and Corruption. We shall comply with all applicable laws, statutes, codes and regulations relating to the prevention of bribery and corruption.

To that end, we shall not accept, offer, promise, pay, permit or authorise:

• bribes, facilitation payments, kickbacks or illegal political contributions;

• money, goods, services, entertainment, employment, contracts or other things of value, in order to obtain or retain an improper advantage; or

• any other unlawful or improper payments or benefits.

Unfair Business Practices. We shall comply with all applicable competition laws, including but not limited to those relating to teaming and information sharing with competitors, price fixing and rigging bids.

Healthcare Compliance. We shall comply with all applicable laws, regulations and codes in our dealings with healthcare professionals, organizations and patient groups.

Procuring and Managing Suppliers. We shall carry out appropriate due diligence on prospective suppliers that will form part of our downstream supply chain. We shall also consider the risk profile of the transaction. At a minimum, the due diligence must include investigations into prospective suppliers’ compliance with applicable laws and other actions on data protection, information security, financial history, human rights, treatment of workers, bribery and ethical behaviour.

Self-monitoring and Reporting Breaches. We encourage everyone to report any concerns or breaches as soon as possible to their line manager. Their line manager will escalate as appropriate. Atlantis Health shall monitor its compliance through senior management with the Code and shall report any breaches (actual or suspected) of this Code as soon as possible to Legal counsel.

No Retaliation

Atlantis Health prohibits retaliation against anyone who reports or participates in an investigation of a possible violation of our Code, our policies, or the law. Please contact a member of senior management if you believe that you are the subject of retaliation within Atlantis Health.