Business Ethics & Anti‑Corruption Compliance Policy

1.Policy Statement

Caresoft conducts business fairly, honestly, and lawfully in every market where we operate. We compete on the merits of our services and solutions — never through bribery, kickbacks, improper payments, or any other corrupt practice. We win business the right way or not at all.

This Policy applies to all Caresoft directors, officers, and employees worldwide, as well as to contractors, consultants, agents, resellers, subcontractors, and any third party acting on Caresoft’s behalf (collectively, “Caresoft Personnel”).

2.Anti‑Bribery & Anti‑Corruption

Caresoft complies with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act 2010, and the local anti-bribery laws of every jurisdiction in which we do business.

Caresoft Personnel must never, directly or through any intermediary:

• Offer, promise, give, or authorize anything of value to improperly influence a decision, obtain or retain business, or secure any improper advantage;
• Solicit or accept any bribe, kickback, or improper payment from any person or entity;
• Make or accept payments intended to induce anyone to violate a duty of loyalty or trust owed to their employer or organization.

“Anything of value” is interpreted broadly and includes cash, cash equivalents, gifts, entertainment, travel, employment or internship offers, charitable or political contributions, favors, and business opportunities.

3.Dealings with Government Officials

Interactions with government officials carry heightened legal risk and are subject to stricter rules than interactions with private commercial parties. For purposes of this Policy, “Government Official” includes any officer or employee of a government, government agency, or state-owned or state-controlled enterprise; any political party, party official, or candidate for office; and any officer or employee of a public international organization.

• No payment, gift, hospitality, or anything of value may be offered or given to a Government Official to influence an official act or decision, or to secure any improper advantage.
• Even nominal courtesies involving Government Officials (such as a business meal) require advance written approval from Caresoft’s compliance leadership.
• Where Caresoft pursues public-sector business — directly or through a partner, prime contractor, or reseller — all applicable procurement laws, lobbying rules, and disclosure requirements must be followed.

4.Facilitation Payments

Caresoft prohibits facilitation or “grease” payments — small payments made to expedite routine governmental actions such as processing permits, visas, or utility connections — even where local law or custom may appear to tolerate them. The only exception is a payment made under an imminent threat to health or safety, which must be reported to Caresoft leadership immediately and accurately recorded.

5.Gifts, Meals & Entertainment

Reasonable and customary business courtesies can play a legitimate role in building professional relationships. However, gifts, meals, and entertainment involving customers, partners, suppliers, or prospects are permitted only when they meet all of the following conditions:

• They are modest in value, infrequent, and appropriate to the occasion;
• They serve a legitimate business purpose and are given openly and transparently;
• They are never in cash or cash equivalents (gift cards, vouchers, loans, securities);
• They could not reasonably be perceived as an attempt to influence a business decision, and are not offered during an active procurement, bid, or contract negotiation involving the recipient;
• They comply with the law and with the known policies of the recipient’s own organization — including the gift and entertainment policies of our technology partners and their customers;
• They are accurately recorded in Caresoft’s books and records.

6.Payment of Commissions & Third‑Party Intermediaries

Caresoft recognizes that commissions, referral fees, and partner incentives paid to or through third parties are a common source of corruption risk. Accordingly:

• Commissions, referral fees, and similar payments may be made only under a written agreement that describes the legitimate services provided and requires compliance with anti-corruption laws;
• Compensation must be reasonable and proportionate to the legitimate services actually rendered, and payable only to the contracting party in the country where services are performed or where the party maintains a bona fide place of business;
• Payments in cash, to personal accounts, to unrelated third parties, or to offshore accounts with no business justification are prohibited;
• Caresoft performs risk-based due diligence before engaging agents, resellers, subcontractors, or referral partners, and will not engage any intermediary it believes may make improper payments;
• Caresoft Personnel must never use a third party to do indirectly what this Policy prohibits Caresoft from doing directly.

7.Accurate Books, Records & Internal Controls

Caresoft maintains books, records, and accounts that accurately and fairly reflect all transactions in reasonable detail. No undisclosed or unrecorded funds or accounts may be established for any purpose. False, misleading, or artificial entries — including mischaracterized commissions, inflated invoices, or disguised gifts — are strictly prohibited. Expenses relating to gifts, meals, entertainment, and third-party payments must be supported by receipts and described truthfully.

8.Conflicts of Interest

Caresoft Personnel must avoid situations where personal, family, or financial interests conflict — or appear to conflict — with the interests of Caresoft or its clients. Actual or potential conflicts, including personal relationships with customer or partner personnel involved in purchasing decisions, must be disclosed to Caresoft leadership promptly.

9.Partner Program & Client Compliance

As a member of technology partner ecosystems, Caresoft commits to conducting its partner-related activities ethically and in compliance with the codes of conduct of the vendors whose programs it participates in, including the Oracle PartnerNetwork and its applicable Partner Code of Ethics and Business Conduct. Where a client’s or partner’s standards are stricter than this Policy, the stricter standard governs.

10.Training, Oversight & Enforcement

Caresoft communicates this Policy to all personnel and provides periodic ethics and anti-corruption guidance appropriate to each role, with particular attention to personnel engaged in sales, procurement, partner management, and public-sector opportunities. Compliance with this Policy is a condition of employment and of doing business with Caresoft. Violations may result in disciplinary action up to and including termination of employment or contract, and may be referred to authorities where required by law.

11.Reporting Concerns & Non‑Retaliation

Every member of Caresoft Personnel has a duty to promptly report suspected violations of this Policy or of applicable law. Reports may be made to any member of Caresoft leadership or through the contact channels below, and may be made in confidence. Caresoft strictly prohibits retaliation of any kind against anyone who raises a concern in good faith or cooperates with an inquiry.