### A. Employee Reporting.

The Practice takes all reports of non-compliance and wrongdoing seriously. The purpose of voluntary disclosure under the Compliance Plan is to provide a mechanism to allow the reporting of any matter that may be unethical, illegal or potentially an issue of non-compliance or wrongdoing without fear by the reporting employee of retribution or embarrassment. With respect to any such matter, every person within the Practice has direct access to and is encouraged to consult with the Compliance Officer.

An employee or agent of the Practice who is requested to make, accept, authorize or agree to any offer, action or payment which is or may be contrary to the compliance program or any of the Practice’s policies shall promptly report such information to the Compliance Officer.

Furthermore, an employee or agent who acquires information that may give rise to a reasonable belief that another employee or agent are engaged in conduct which violates the compliance program or any of the Practice’s policies or that an agent, representative or other person or firm representing the Practice in any transaction is engaged in the type of conduct which does not meet the standards set forth in the compliance program or any of the Practice policies shall also promptly report such information to the Compliance Officer.

Reports to the Compliance Officer shall be made in person, by telephone, by voice mail or by mail to the Compliance Officer. A sample “report” form that may be used by the reporting person is attached hereto as Exhibit C.

The Compliance Officer shall maintain a notebook “log” of all reports regarding compliance matters. These reports shall be assigned a sequential file identification number by the Compliance Officer for the specific year and shall be used for new or additional information on the same matter. The caller/author shall not be required to provide his/her name or any other facts that may give away his/her identity. If the caller/author provides his/her identity, then he/she shall be provided with the file identification number for the reported matter on a confidential basis. The caller/author shall be encouraged to provide as much information as possible to assist with the investigation of the matter. The caller/author shall also be advised that the Compliance Officer will use best efforts to keep the identity of the caller/author confidential; however, there may be a point in time when the individual’s identity may become known or may have to be revealed.

The Compliance Officer shall conduct an investigation of the report, make a record in the log of the results and the specific actions taken after completion of the investigation. The specific facts and circumstances surrounding the report must be kept confidential and any discussions regarding the complaints should be limited to those parties with a “need to know” during the investigation. Upon final resolution of a problem, the Compliance Officer shall provide feedback to an appropriate administrative official regarding the possible need for policy or procedure change. In addition, the Compliance Officer shall prepare annual reports to be submitted to the Board of Directors on the status of the Compliance Program.

IT IS THE PRACTICE’S POLICY THAT NO EMPLOYEE SHALL SUFFER ANY PENALTY OR RETRIBUTION FOR THE GOOD FAITH REPORTING OF ANY

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