Vanguard Healthcare Services and it's affiliates are committed to abiding by the highest legal and ethical standards in serving the residents of our facilities. Meeting this commitment requires efforts of highly-skilled caregivers and dedicated support staff. Our employees must daily earn the respect and trust of residents and others by conducting themselves with honesty and integrity. So, they must demonstrate behaviors consistent with the Company’s mission and values, while adhering to all applicable federal, state and local laws.

Vanguard acknowledges that to have an effective Compliance and Ethics Program, we must consistently do the following:

• Develop and implement policies, procedures and practices designed to promote the Compliance and Ethics Program and to monitor the day-to-day activities of Vanguard and its affiliates to ensure compliance with such policies, procedures and practices.
• Exercise due diligence to prevent and detect improper or illegal conduct.
• Promote a culture that encourages ethical conduct and a commitment to compliance with the law.
• Periodically assess the risk of improper or illegal conduct.
• Take appropriate steps to design, implement or modify the Compliance and Ethics Program to reduce the risk of improper or illegal conduct identified through the compliance process.
• Educate all associates, vendors, contractors and physicians on the Compliance and Ethics Program and Code of Business Conduct and make a copy of these documents available to any of the above individuals.
• Promote compliance with all applicable laws and regulations by independent contractors, vendors and others that do business with Vanguard.

The Compliance and Ethics Program is designed to meet or exceed the elements of an effective compliance program as set forth in the Compliance Program Guidance for Nursing Facilities, developed by the U.S. Department of Health and Human Services’ Office of Inspector General, published on March 16, 2000, which identifies the basic elements an organization should have in its program.