Compliance

New Amsterdam Drug Mart Inc is dedicated to maintaining a communication structure that will enable us to effectively detect, prevent and correct FWA. All affected individuals including but not limited to employees are required to report compliance concerns and suspected or actual misconduct to the compliance officer: New Amsterdam Drug Mart Address: 698 Amsterdam Ave. New York, NY 10025 Ph:212-865-9700

Section 6

Reporting FWA

    1. Internal Employee Reporting

This section focuses on reporting violations of Fraud, Waste and Abuse. New Amsterdam Drug Mart, Inc is committed to identifying and limiting fraud, waste and abuse and has set up a communications process for all affected individuals including but not limited to employees to report any questionable activity or potential violation that arises so that it may be addressed quickly in the appropriate manner.

All New Amsterdam Drug Mart, Inc affected individuals including but not limited to employees must report any suspected fraud, waste and abuse violation immediately to New Amsterdam Drug Mart, Inc's Compliance Officer. All affected individuals including but not limited to employees may obtain an FWA Suspicious Activity Report form from the Compliance Officer or they may provide information in another format that they may be more comfortable with. All affected individua,ls including but not limited to employees may submit information anonymously or they may request that the Compliance Office hold their identity in confidence.

Employees will find the reporting forms in the FWA binder. They will report to compliance officer and also to the owner

We believe these options and procedures encourage and promote all affected individuals including but not limited to employees to report any suspicion of fraud, waste and abuse; ultimately producing a safe atmosphere of honesty, directness and good ethical standards. Failure to report suspected compliance problems shall result in enforcement of disciplinary policies.

    1. External Employee Reporting

There may be circumstances when a New Amsterdam Drug Mart, Inc affected individual including but not limited to an employee would be uncomfortable reporting a suspicious activity to the Compliance Officer. Sometimes suspected activities may involve a supervisor, manager, owner or even the Compliance Officer. In such cases, all affected individuals including but not limited to employees may elect to contact a resource outside of New Amsterdam Drug Mart, Inc. A branch of the Department of Health and Human Services (DHHS), the Office of the Inspector General (OIG) maintains a Hotline for reporting suspected Fraud, Waste and Abuse at 1-800-HHS-TIPS (1-800-447-8477). The FWA Hotline number is posted in the pharmacy.

    1. Whistleblower Protections and the False Claims Act

New Amsterdam Drug Mart, Inc will work diligently to achieve an atmosphere where all affected individuals including but not limited to employees feel comfortable reporting any potential fraud, waste and abuse without fear of repercussions. New Amsterdam Drug Mart, Inc pledges to its affected individuals including but not limited to employees who file a report of a suspicious activity or involved in an investigation, audit, self­ evaluation or remedial action that we protect them from retaliation (or intimidation) and are committed to protecting the rights of all affected individuals including but not limited to employees. We are committed to abide by all State and Federal regulations that protect whistleblowers and in particular the Federal False Claims Act. The False Claims Act contains provisions to protect whistleblowers from retaliation.

New Amsterdam Drug Mart, Inc takes the following steps to protect all affected individuals including but not limited to employees who report suspected FWA from retaliation (or intimidation):

      • Any Employee found to intimidate or retaliate against the reporting employee will face discipline up to and including immediate termination of employment.
      • The Compliance Officer will conduct interviews in secure, private areas so as to avoid compromising the identity of the reporting employee.
      • Shall comply with requirements of Sections 740 and 741 of New York State Labor Law in regards to protecting all affected individuals from intimidation or retaliation for good faith participation in this compliance program.

New Amsterdam Drug Mart, Inc

Code of Conduct, Business Ethics and Conflict of Interest Policy

EFFECTIVE March 14, 2025

Who Must Follow This Code?

This Code of Conduct, Business Ethics and Conflict of Interest Policy {herein referred to as "Code") is applicable to New Amsterdam Drug Mart, Inc, its owners, officers, agents and all affected individuals including but not limited to employees. The reputation, respect and standing within the community served by New Amsterdam Drug Mart, Inc is the result of our dedication to professional and business standards of the highest integrity.

Your Personal Pledge to Do the Right Thing

The Code represents a commitment to doing what is right. By working for New Amsterdam Drug Mart, Inc, you are agreeing to uphold this commitment; you understand the standards of the Code and will always follow them. If you fail to follow these standards you place New Amsterdam Drug Mart, Inc, your fellow coworkers and yourself at risk. This Code of Conduct is more than just a description of our standards; it is the centerpiece of our compliance and integrity program and assures that all of us conduct business with the highest standards of integrity.

Honest and Ethical Conduct

New Amsterdam Drug Mart, Inc is committed to honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships. We recognize that New Amsterdam Drug Mart, Inc is harmed when the real or apparent private interest of an owner, officer, agent or affected individuals including but not limited to an employee is in conflict with the interests of New Amsterdam Drug Mart, Inc. This occurs, for example, when someone receives improper personal benefits as a result of their position with New Amsterdam Drug Mart, Inc, or has other duties, responsibilities, or obligations that run counter to their duty to New Amsterdam Drug Mart, Inc.

Conflicts of Interest

A "conflict of interest" arises when a personal, social, financial or political activity has the potential of interfering with your loyalty and objectivity to New Amsterdam Drug Mart, Inc. Actual conflicts must be avoided; even the appearance of a conflict of interest can be harmful and should be avoided. Our Policy & Procedure Manual describes common ways that conflicts of interest can arise. If affected individuals including but not limited to employees are unsure if a "conflict of interest" may exist, ask New Amsterdam Drug Mart, Inc's management, for permission first. It is better to make sure the action is appropriate rather than hoping for forgiveness after the fact.

New Amsterdam Drug Mart, Inc Opportunities

All affected individuals including but not limited to employees, officers and directors may not use New Amsterdam Drug Mart, Inc or New Amsterdam Drug Mart, Inc's property or proprietary information, or their positions with New Amsterdam Drug Mart, Inc, for personal gain. You should never take or claim as your own business opportunities that you learn about through your work for New Amsterdam Drug Mart, Inc. Also, never engage in any business activities that compete with New Amsterdam Drug Mart, Inc.

Receiving Gifts and Entertainment

Relationships with others must be based entirely on sound business decisions and fair dealing. Business gifts and entertainment can build goodwill, but they can also make it harder to be objective about the person providing them. In short, gifts and entertainment can create their own "conflicts of interest." All affected individuals including but not limited to employees of New Amsterdam Drug Mart, Inc must follow the written procedures regarding acceptable and unacceptable gift giving and receiving.

Financial Integrity

New Amsterdam Drug Mart, Inc always strives to retain the trust of our affected individuals including but not limited to employees and business associates. Any invoices, claims for payments, reports and documents that New Amsterdam Drug Mart, Inc submits to any governmental agency or business associate shall always be full, fair, accurate, timely and understandable.

Accurate and Complete Books, Records and Accounting

New Amsterdam Drug Mart, Inc's credibility is judged in many ways-and one very important way is the integrity of its books, records and accounting. In addition to our own commitment to accurately report financial performance, New Amsterdam Drug Mart, Inc is required by law to follow generally accepted accounting principles.

Every affected individuals including but not limited to employee of New Amsterdam Drug Mart, Inc must ensure that the reporting of business information, electronic, paper or otherwise, is accurate, complete and timely. This includes accurately booking costs, sales, time sheets, vouchers, bills, payroll and benefits records, regulatory data and other essential New Amsterdam Drug Mart, Inc information.

In addition, all affected individuals including but not limited to employees must:

  • Never deliberately make a false or misleading entry in a report or record.
  • Never alter or destroy New Amsterdam Drug Mart, Inc records except as authorized by established policies and procedures.
  • Never sell, transfer or dispose of New Amsterdam Drug Mart, Inc assets or any New Amsterdam Drug Mart, Inc confidential information without proper authorization and documentation.
  • Cooperate with New Amsterdam Drug Mart, Inc's Compliance Officer and any investigation by the Compliance Officer.
  • Contact the New Amsterdam Drug Mart, Inc Management or New Amsterdam Drug Mart, Inc's Compliance Officer with any questions about the proper recording of financial transactions.
  • Never encourage, direct, facilitate or permit non-compliant, illegal or unethical behavior.

If you have a concern about a legal or business conduct issue, you are obligated to report and raise the issue with New Amsterdam Drug Mart, Inc's Compliance Officer.

We All Must Follow the Code of Conduct and Government Laws and Regulations.

All affected individuals including but not limited to employees who perform work for New Amsterdam Drug Mart, Inc shall be held accountable for complying with applicable laws, government rules, regulations, including Medicare Part D and this Code. In addition, all affected individuals including but not limited to employees shall be committed to following New Amsterdam Drug Mart, Inc's Fraud, Waste and Abuse Compliance Program to prevent, detect, report and correct fraud, waste and abuse to the maximum extent possible. New Amsterdam Drug Mart, Inc does not employ any person who has been excluded from participating in any government funded program. New Amsterdam Drug Mart, Inc runs a background search of both the Office of the Inspector General's and General Service Administration's Exclusion Lists to screen new hires prior to employment and all affected individuals including but not limited to employees on a monthly basis.

Unauthorized Release of Confidential Information

Unauthorized release of confidential New Amsterdam Drug Mart, Inc information, including, but not limited to, proprietary information, lists, contracts, financial information, or patient personal health information; shall be considered a major violation of the Code.

Any owner, officer, agent or affected individuals including but not limited to employees of New Amsterdam Drug Mart, Inc that releases confidential information without authorization may be terminated from employment.

Enforcement: Discipline Imposed for Violations

Violations of this Code are subject to discipline by New Amsterdam Drug Mart, Inc Management including oral and written warnings, reprimands, suspensions, terminations and financial penalties. The Compliance Officer

and Management of New Amsterdam Drug Mart, Inc reserve the right to determine the appropriate discipline to fit the circumstances. Violations shall be dealt with swiftly and illegal acts of violators may be reported to the authorities as appropriate. Enforcement of the Code shall be prompt and consistent, applying appropriate standards and processes as determined.