The HCA Healthcare Code of Conduct (the "Code") provides guidance to all HCA Healthcare colleagues and helps us carry out our daily activities within appropriate ethical and legal standards. These obligations apply to our relationships with patients, affiliated physicians, third-party payers, subcontractors, independent contractors, vendors, consultants and one another.

The Code is a critical component of our overall ethics and compliance program. We have developed the Code to ensure we meet our ethical standards and comply with applicable laws and regulations.

The Code is intended to be comprehensive and easily understood. In some instances, the Code deals fully with the subject covered. In many cases, however, the subject discussed has so much complexity that additional guidance is necessary. To provide additional guidance, we have developed a comprehensive set of compliance policies and procedures, which expand upon or supplement many of the principles articulated in the Code of Conduct. Though we promote the concept of management autonomy at local facilities in order to meet local needs, the standards set forth in the Code are mandatory and must be followed.