ASPEN LAKE MEDICAL EQUIPMENT & OPTIMAL DME
(“ASPEN LAKE” OR “COMPANY”)
ETHICS & COMPLIANCE STATEMENT
At Aspen Lake, we are committed to excellence and quality in all our operations. Upholding compliance with sound business practices is our top priority, and we are dedicated to maintaining the highest standards of ethics in our interactions with patients, payors, employees, and the public. Accordingly, Aspen Lake conducts its business in alignment with the following two core principles:
PATIENT CARE AND COMPLIANCE WITH ALL LAWS
(OUR “COMPLIANCE MANDATE”).
Aspen Lake adheres to a zero-tolerance policy for any violations of our Compliance Mandate. Our employees, contractors, and affiliated individuals are required to act in accordance with the highest standards of patient care and to fully comply with all relevant laws and compliance requirements. We will not engage in any business activity that involves unethical or illegal conduct. To enforce our Compliance Mandate, our compliance program incorporates the seven key elements of an effective compliance program, including: (1) written standards of conduct and policies that promote commitment to compliance; (2) a Compliance Officer(s) responsible for overseeing the program; (3) compliance education and training for all new hires, with annual updates for staff; (4) processes for receiving complaints and allowing staff to report concerns without fear of retaliation; (5) responding to allegations of improper activities and, when necessary, developing corrective action plans; (6) auditing and monitoring to identify potential risks; and (7) investigating and remedying identified systemic issues and ensuring that no sanctioned individuals are employed.
To support and strengthen our Compliance Mandate and these elements, we have established various policies and compliance practices, including the adoption of our Code of Ethics and Business Conduct (“Code”). The Code applies to all Aspen Lake employees, contractors, suppliers, and officers and is designed to provide guidance on complying with laws, regulations, and company policies. We regularly communicate with employees about the Code to ensure familiarity and awareness and require employees to annually certify their commitment to adhering to the policy.
The Code and stand-alone policies also include specific anti-retaliation provisions to protect employees who come forward with concerns. We encourage open communication of issues and are committed to protecting anyone who reports inappropriate business practices in good faith. Any retaliation against individuals making reports or participating in investigations will result in disciplinary action.
In addition to the Code, we provide ongoing training tailored to employee roles and functions. Training, which may be conducted in person or online, covers compliance topics such as anti-kickback, false claims, Stark Law, improper inducements, and other relevant laws. Training also addresses conflicts of interest, privacy, anti-discrimination, anti-corruption, and guidelines for gifts and hospitality. Completion of required training is monitored and refreshed regularly. We also mandate periodic certifications by management-level employees regarding adherence to company policies and various compliance topics. These practices complement the Code and offer role-specific guidance to employees.
Aspen Lake recognizes the significance of effective oversight of potential business risks for successful operations and meeting our obligations to patients, payors, practitioners, and the public. We are responsible for fostering a strong culture of risk management and actively oversee our aggregate risk exposure, addressing specific risks including competitive, legal, regulatory, operational, and financial risks.
In summary, our Compliance Program embodies Aspen Lake’s commitment to: (1) providing education, policies, and tools for best patient care and compliance with all laws; (2) conducting periodic investigations and responding to any indications of misconduct; (3) monitoring company activities, including internal audits to assess risk; and (4) adopting a proactive approach to compliance to uphold Aspen Lake’s Compliance Mandate. We are dedicated to ensuring the highest standards of patient care and adherence to all laws and ethical practices.