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Code of Ethics

Welcome Message from the CEO

Dear Colleagues,

At Akumin, we are firmly committed to operating in compliance with all governing laws and regulations. We act ethically and with integrity as we focus on delivering high-quality patient care in the communities we serve. The behaviors and actions of each individual are foundational to our ability to meet this commitment.

This Code of Ethics, as well as each of our policies, are here to ensure that each team member understands (i) the expectations of you, (ii) how to speak up, and (iii) where to seek help should you need to.

What we do and how we do it matter greatly to all of our patients, healthcare providers, partners, and everyone with whom we engage. Each of you must read, understand, and acknowledge this Code, and incorporate its values, standards, and requirements into your daily work activities. Each of you is expected to exercise good judgment and to speak up with any questions or concerns regarding any business, legal, or ethical concerns you may encounter. This will help us ensure that we protect and maintain our role as a trusted healthcare service provider and partner.

Like all healthcare entities, we face business and legal risks every day that could adversely affect our company, as well as each one of us personally. By adhering to this Code and our policies, and by behaving ethically and in compliance with all applicable laws and regulations, you minimize the risk of violations and increase the likelihood that we will continue to operate for the benefit of our patients and healthcare providers and partners.

Thank you for your efforts and contributions in serving those who utilize, rely on, and benefit from Akumin’s first-in-class care, services, and treatments.

Henry Howe
Chief Executive Officer

‌Overview of this Code of Ethics‌‌‌‌

Who Must Read, Acknowledge & Follow this Code?

This Code applies, without exception, to all Akumin employees regardless of title or role, as well as to our business partners and third parties that conduct business on our behalf (collectively, “Team Members” or “you”). Adherence to this Code and all our policies is a condition of employment for our Team Members and a condition of engagement for our business partners and third parties who conduct our business. If you have any questions about this Code, please speak with your Manager/Supervisor, your Human Resources (“HR”) business partner, our Compliance Department (compliance@akumin.com), or our Legal Department (legal@akumin.com).

What is the Purpose of this Code?

The purpose of this Code is to clearly communicate our commitment to conducting all business with honesty and integrity, in compliance with applicable laws, regulations, and our policies, and in a manner that preserves Akumin’s reputation and deters any misconduct or wrongdoing. Akumin strives to provide excellent care of our patients in an excellent working environment for our Team Members. We are providing this Code so that you are aware of and understand the general obligations, standards, and expectations that should guide you in carrying out your duties for and on behalf of Akumin. It is not intended to cover every issue that may arise, and some items covered in this Code may also be addressed in other Akumin policies. If you’re unsure whether a particular issue is covered by this Code or other Akumin policies, please speak with your Manager/Supervisor, your HR business partner, our Compliance Department (compliance@akumin.com), or our Legal Department (legal@akumin.com).

Why is the Code Important?

How we conduct our business in providing high-quality patient care is equally as important as the success of our business, and we want to ensure that you understand your duties and obligations to conduct all business in a compliant manner and reduce the risk of misconduct or wrongdoing. All Team Members are required to fully familiarize themselves with and follow this Code and our policies to:

  • ‌Ensure the best possible service, care, and treatment for our patients,‌
  • Preserve our reputation and integrity as a company that puts the needs of patients first,
  • Maintain a work environment that fosters our shared responsibility to achieve our best work with integrity and in a legal and compliant manner, all for the benefit of our patients, and
  • Encourage and require reporting (directly or anonymously) of any actual or suspected unethical behavior, misconduct, or wrongdoing. We take all reports seriously, and will investigate, make corrective changes, and/or take disciplinary action, as appropriate based upon the relevant facts and circumstances.We will not tolerate and will appropriately address any intentional unethical behavior, misconduct, or wrongdoing that is contrary to any laws or regulations, this Code, or our policies.

How to Make the Right Decision?

If you’re in a situation or at a decision point and unsure what to do, ask yourself:

  • Is the contemplated action or decision contrary to any laws or regulations, this Code, or our policies? Note: If any provision in this Code or our polices is more “strict” than what is required by applicable laws or regulations, you must comply with this Code and our policies.
  • Would the action or decision make Akumin or you appear to be acting in an unethical, unlawful, or improper manner?
  • Could the action or decision cause harm to either Akumin’s or your reputation? If your answer is “yes” to any one of these questions, you need to speak up! It is your duty and obligation to do so. You should not proceed before and until you discuss the matter with your Manager/Supervisor, your HR business partner, our Compliance Department (compliance@akumin.com), or our Legal Department (legal@akumin.com). They will provide guidance, and you are required to follow that guidance.

‌It’s Your Duty to Speak Up About Actual or Suspected Wrongdoing or Violations!‌

You are required to adhere to Akumin’s commitment to conducting business ethically, with integrity, and in compliance with all governing laws and regulations, as well as with this Code and our policies. Whenever you become aware of an actual or suspected violation of any laws or regulations, this Code, or our policies – or you have a good faith belief that such a violation or any other wrongdoing has or may take place – you are required to report the matter. To assist you, we offer a number of reporting avenues, including options to report anonymously. You are free to use whichever method you prefer, but your obligation to report is not optional. Here are the different ways for you to report:

Anyone who makes a report online or by phone to the Compliance Hotline may choose to remain anonymous, if they wish.

Whether you file a report anonymously or choose to provide your name, you should always provide all the details you know as soon as you learn them so the issue can be assessed appropriately. If you become aware of any additional facts or details after filing your report, you should update your report with that information. You are strictly forbidden from conducting any investigation on your own or from taking any proactive steps to obtain additional information after you have reported the matter. You are, however, required to cooperate fully in any ensuing investigation by Akumin.

‌Whenever you file a report, Akumin will be notified of your report. We will then assess and, as appropriate, investigate, address any matters that need to be resolved, and/or take action to prevent future occurrences.‌‌

Depending on the circumstances, we may employ corrective and preventative steps, such as training, counseling, enhanced controls, and disciplinary action up to and including termination of employment or business relationship.

Please be aware that Akumin will not take any steps to identify a reporter who submits an anonymous report in good faith. And Akumin will not tolerate any form of retaliation against someone who reports an issue in good faith. No exceptions.

What Are the Potential Consequences of Failure to Comply with this Code or Akumin’s Policies?

Failure to abide by this Code or Akumin policies may lead to disciplinary action. In investigating alleged or suspected violations, Akumin will consider the relevant facts and circumstances, including the extent to which the behavior was contrary to this Code or our policies, the seriousness of the behavior, the actual or potential harm, the individual’s or entity’s history with Akumin, and any other relevant factors. Discipline for failure to abide by this Code or our policies may range from a warning to termination for our Team Members. In the case of Akumin’s business partners and all third parties that conduct business on our behalf, disciplinary action may include contract termination where applicable.

What Should You Do If You Think Your Situation Merits an Exception to this Code or Our Policies?

If you believe you are facing a situation that is extraordinary and constitutes grounds for operating outside the requirements and obligations of this Code or our policies, you may seek an exception. First, discuss the matter with your Manager/Supervisor. If your Manager/Supervisor supports the request, you must submit a written request, along with all the relevant facts and the reasons why you believe an exception should be made, to our Compliance Department (compliance@akumin.com). You may not proceed with your requested exception or action unless and until you receive a written response from our Chief Compliance Officer or an attorney from our Legal Department advising that your request has been approved along with any additional instructions regarding how you should proceed.

‌Conducting Business with Ethics & Integrity‌‌‌‌

Standards of Ethics, Integrity & Professionalism

All Team Members are required to carry out our business activities ethically and with integrity. When conducting Akumin business, you must always act in an honest and direct manner, and you must avoid even the appearance of misconduct or improper behavior.

You are also expected and required to act professionally, to treat others respectfully, and to communicate in a way that upholds Akumin’s reputation and integrity, as well as your own, including on all forms of social media.

Compliance with Applicable Laws, Regulations, this Code & Policies

You are required to be familiar and comply with all applicable laws and regulations in every place where we conduct business activities and you carry out your duties. Beyond those legal obligations, this Code and our policies set forth additional requirements and guidelines that should always govern your business activities. If you have any questions about the applicable laws and regulations, this Code, or our policies, you should speak with your HR business partner, our Compliance Department (compliance@akumin.com), or our Legal Department (legal@akumin.com).

Fair Dealing

All business dealings must be conducted in a manner that preserves Akumin’s reputation and integrity. You should avoid making any misrepresentations of material fact, misusing or disclosing any confidential information, or engaging in any illegal, unethical, or unfair business practices when conducting Akumin business.

‌Avoiding Conflicts of Interest‌‌‌

It is vitally important that you perform your duties and arrange your personal matters so they do not interfere with your independent exercise of judgment when conducting Akumin business. It is also essential to act honestly and in good faith at all times, and you must place Akumin’s best interests first. In other words, you must never put your, your family’s, or any other outside business interests ahead of Akumin’s interests.

You also should stay on the lookout for situations that may involve an actual or even a potential conflict of interest. If you become aware of any situation where an actual or potential conflict of interest may exist (whether it is something that has already taken place, is about to take place, or may take place), you are required to report the matter promptly – and absolutely no more than 24 hours after discovering or otherwise becoming aware of the situation – to your Manager/Supervisor, your HR business partner, our Compliance Department (compliance@akumin.com), or our Legal Department (legal@akumin.com).

If it is determined that an actual or potential conflict exists, you will receive direction as to how to handle the situation, and you are required to follow and/or comply with those and any other directions you receive as a result of your report.

Refraining from Corporate Opportunities

You may not take advantage of or accept any personal opportunities that arise through the use of Akumin’s property or information, and you may never use Akumin’s property or information for your own, your family’s, or any outside or other business’s use or gain.

Additionally, you are prohibited from competing with Akumin, directly or indirectly, and you owe a duty and are obligated to advance the legitimate interests of Akumin alone when business opportunities arise in the course of your work for, or on behalf of, Akumin.

Meals, Gifts, Gratuities & Entertainment

As a general rule, and with only five expressly defined and limited exceptions (set forth below), you are strictly forbidden from giving or receiving anything of value (including, but not limited to meals, entertainment, gifts, benefits, gratuities, free or reduced-fee services, favors, special accommodations, cash or cash equivalents, or other items of value), to or from any healthcare partners, healthcare providers, vendors, agents, competitors, customers, or patients if even one purpose may be viewed as being for the referral of business.

The five limited exceptions may occur where:

  1. / Meals. Meals are permitted when the cost is modest and within the applicable Akumin-set caps/limits and guidelines, the purpose of the meal is educational only, and all expenses are itemized and accurately recorded (with all required fields) in Concur.
  2. / Nominal gifts. Token gifts, such as books, flowers/plants, small gift baskets, etc., are permitted when they are given on a special occasion, such as a birthday or holiday, the cost is modest and within the Akumin-set caps/limits and guidelines, and all details are itemized and accurately recorded in Concur.
  3. / Contract-based payments. Payments (never cash or cash equivalents) are permitted when they are made pursuant to an Akumin-authorized and approved written contract that reflects fair market value and is for a legitimate and recognized business purpose that is not tied to the referral of business.
  4. / Reduced-fee services. Reduced-fee services (for whatever reason, including reduced-fee services for indigent or uninsured patients and discounts made for a legitimate business purpose, such as to provide a credit for a deficient service) are permitted only when they are approved in writing and in advance by Akumin’s Chief Compliance Officer or Chief Medical Officer, are within the applicable Akumin-set caps/limits and guidelines, both the service and discount are properly documented and disclosed in cost reports, and no purpose of the reduced-fee is to induce referrals.
  5. / Charitable Contributions. Contributions to bona fide 501(c)(3) charitable organizations or entities that support such organizations are permitted when they are approved in writing and in advance by Akumin’s Chief Financial Officer and within the applicable Akumin-set caps/limits and guidelines.

If you are unsure whether a particular expenditure or transfer of value fits within the above five narrow exceptions, please confirm with your Manager/Supervisor or with our Compliance Department (compliance@akumin.com) before committing to or actually incurring the expense. To re-emphasize: Even expenditures permitted pursuant to an exception must comply with any caps/limits set by Akumin and, in certain instances, must be pre-approved, as set forth above. If Akumin has an internal standard that is more stringent than what is required by law or regulation, all Team Members must follow Akumin’s higher standard.

‌Privacy of Personal Information‌

In the course of conducting business, we routinely collect and store personal information about certain groups of people (such as Team Members, business partners, healthcare professionals, patients, and others), including contact information, birth dates, and financial, medical, and other information. When we collect and process personal information, we do so in compliance with applicable laws and regulations, as well as our privacy, data- protection, and other policies. All personal information collected must only be used for legitimate business purposes, shared only with the “minimum necessary” individuals and only the “minimum necessary” amount (as set forth in HIPAA’s Privacy Rule), protected in accordance with our security policies, and retained only for as long as necessary and in accordance with our retention policies. We also must ensure that third parties with access to any collected personal information are contractually obligated to protect it in accordance with all of the above privacy and data-security requirements and standards.

‌Fair Treatment & Safety‌‌‌

Equal Opportunities, Non-Discrimination & Preventing Harassment/Bullying

We are committed to providing a workplace in which all individuals are treated with dignity and respect. Everyone has the right to work in a professional atmosphere that promotes equal opportunities and is free from discrimination and harassment/bullying on the basis of race, color, gender, religion, national origin, age, disability, pregnancy, sexual orientation, marital status, veteran status, genetic information, or any other characteristics protected by law.

Be mindful that harassment and bullying can take many forms, including off-color jokes, threats, loud or abusive statements, unwanted physical actions, and any sexual conduct or discussion, to name a few. You should always stay focused on business matters and act in a professional manner when conducting Akumin business.

Ensuring Safety & Security

We are committed to providing a safe and healthy work atmosphere that complies with all applicable laws and regulations, and Akumin will not tolerate threats, violence, dangerous or intimidating behavior, abusive language or conduct, or any other activities that negatively affect safety and security. At the same time, you are responsible for prioritizing your health and safety, and you are required to promptly report any unsafe conditions and any accidents or incidents to your Manager/Supervisor, your HR business partner, our Compliance Department (compliance@akumin.com), or our Legal Department (legal@akumin.com) so they may be assessed, addressed, and/or remedied, as appropriate.

A significant threat to the safety and security of our work atmosphere and business operations is alcohol and drug misuse. Any alcohol use and/or drug misuse by Team Members while conducting Akumin business can endanger the health, safety, and security of our patients, other Team Members, and our business; adversely affect the quality and effectiveness of our business operations; and pose a real risk of harm to Akumin’s reputation and integrity. With the sole exception of work events where alcohol is served (where alcohol consumption by Team Members should be limited to a modest amount), Akumin strictly forbids the use of alcohol and/or the misuse of drugs (prescribed, unprescribed, or illegal) at all times and places where Akumin business is being conducted.

‌Protecting Our Assets‌‌‌

Protecting & Proper Use of All Akumin Assets

Akumin’s assets include all data and information (confidential or otherwise), records, “know-how,” intellectual property, facilities, inventory, and equipment, among other things. You must treat all our assets with the strictest integrity and with due regard to Akumin’s interests.

You must ensure they are used solely for legitimate business purposes; the only exception is that Team Members may make incidental or limited use of Akumin computers and telephones while on work breaks, such as to locate an address or phone number on the Internet or to place or receive a brief personal call. However, even incidental or limited use must be appropriate for a business setting and not inappropriate in any way. And none of our assets may ever be used for personal gain or benefit, for the gain or benefit of any family members, or for any business purposes unrelated to Akumin. Put simply, you are required to act in a manner that protects our assets from loss, damage, misuse, theft, misappropriation, disparagement, or waste.

Protecting Proprietary & Confidential Information

One of our most important assets is our proprietary and confidential information, including information about our business strategies, assets, opportunities, joint venture or other business arrangements, vendors, agents, and competitors, and all other business-sensitive information. In the course of your work, you may learn information about Akumin that is proprietary and confidential, or you may learn proprietary and confidential information that has been shared with Akumin by others.

You are required to take all necessary steps to ensure that you safeguard and protect all proprietary and confidential information from any unauthorized or inadvertent disclosure. For example, you should avoid talking about or sharing such information in public places, including in elevators, airports, and restaurants. Additionally, you should always store proprietary and confidential business on authorized or managed devices and send such information outside Akumin only to authorized recipients and in a secure manner using Akumin-approved devices and methods.

Moreover, you should never post or discuss any information concerning our business (previous, present, or prospective) on the Internet. You must never discuss our business in any “chat room” or on any social media platform (regardless whether you use your own name or a pseudonym). And you should treat all Akumin emails, voice messages, chats/ instant messages, and any other Akumin-related communication as confidential.

If you know or suspect that there has been a theft or unauthorized disclosure of, or unauthorized access to, Akumin information, you should immediately report the matter to your Manager/Supervisor, to our Chief Information & Security Officer (IT-security@akumin.com), or to our Compliance Department (compliance@akumin.com) or Legal Department (legal@akumin.com).

‌Compliance with, and Violations of, this Code‌‌‌‌

What Should You Do If You Have Any Questions?

If you have any questions about any parts of this Code or how the Code should be followed in a particular case, please ask your Manager/Supervisor, your HR business partner, our Compliance Department (compliance@akumin.com), or our Legal Department (legal@akumin.com).

What Should You Do If You Think Your Situation Merits an Exception to this Code or Our Policies?

If you believe you are facing a situation that is extraordinary and constitutes grounds for operating outside the requirements and obligations of this Code or our policies, you may seek an exception. First, discuss the matter with your Manager/Supervisor. If your Manager/Supervisor supports the request, you must submit a written request along with all the relevant facts and the reasons why you believe an exception should be made to our Compliance Department (compliance@akumin.com). You may not proceed with your requested exception unless and until you receive a written response from our Chief Compliance Officer or an attorney from our Legal Department advising that your request has been approved along with any additional instructions regarding how you should proceed.

How to Report Actual or Suspected Violations?

You are required to adhere to Akumin’s commitment to conducting business ethically, with integrity, and in compliance with all governing laws and regulations, as well as with this Code and our policies. Whenever you become aware of an actual or suspected violation of any laws or regulations, this Code, or our policies – or you have a good faith belief that such a violation or any other wrongdoing has or may take place – you are required to report the matter. To assist you, we offer a number of reporting avenues, including options to report anonymously. You are free to use whichever method you prefer, but your obligation to report is not optional. Here are the different ways for you to report:

Anyone who makes a report to the Compliance Hotline may choose to remain anonymous, if they wish.

Whether you file a report anonymously or choose to provide your name, you should always provide all the details you know as soon as you learn them so the issue can be assessed appropriately. If you become aware of any additional facts or details after filing your report, you should update your report with that information. You are strictly forbidden from conducting any investigation on your own or from taking any proactive steps to obtain additional information after you have reported the matter. You are, however, required to cooperate fully in any ensuing investigation by Akumin.

Whenever you file a report, Akumin will be notified of your report. We will then assess and, as appropriate, investigate, address any matters that need to be resolved, and/or take action to prevent future occurrences. Depending on the circumstances, we may employ corrective and preventative steps, such as training, counseling, enhanced controls, and disciplinary action up to and including termination of employment or business relationship.

Please be aware that Akumin will not take any steps to identify a reporter who submits an anonymous report in good faith. And Akumin will not tolerate any form of retaliation against someone who reports an issue in good faith. No exceptions.

‌What Are the Potential Consequences of Failure to Comply with this Code or Akumin’s Policies?‌

Failure to abide by this Code or Akumin policies may lead to disciplinary action. In investigating alleged or suspected violations, Akumin will consider the relevant facts and circumstances, including the extent to which the behavior was contrary to this Code or our policies, the seriousness of the behavior, the actual or potential harm, the individual’s or entity’s history with Akumin, and any other relevant factors. Discipline for failure to abide by this Code or our policies may range from a warning to termination for all Team Members.

In the case of Akumin’s business partners and all third parties that conduct business on our behalf, disciplinary action may include contract termination where applicable.

Please note that we are committed to continuously reviewing and updating our Code and policies. If you have any questions about whether you are reading the most current Code or policies, please visit Akumin Insight, where it is posted. For those outside Akumin, the current Code may be found on our website.

‌Akumin Team Member Acknowledgement‌

Akumin has established this Code of Ethics to set forth our standards of business and professional conduct, our ethical values, and our commitment to compliance with all applicable laws and regulations, as well as all our policies. Our primary business is providing the best possible service, care, and treatment for our patients, and we must conduct all business operations legally and ethically to ensure we are able to provide first-in-class patient care.

All Team Members (regardless of title or role), business partners, and third parties that conduct business on our behalf are expected to be familiar with and understand this Code and our policies, as well as to fulfill the duties and obligations described in those documents.

Acceptance and compliance with this Code and our policies is an affirmative obligation and a condition of employment for our Team Members. Failure to abide by this Code and our policies, or violation of their terms, may lead to disciplinary action, up to and including termination.

Failure to comply with this Code and our policies by our business partners and all third parties that conduct business on our behalf may result in disciplinary action, up to and including contract termination where applicable.

‌Document Review History‌‌‌

Approvals

Version # 2025.01
Approved By Compliance Committee
Approval Date 03/03/2025

Document History

The “Code of Ethics” policy version 2025.01 replaces any and all prior versions of the “Code of Conduct” policy.

Policies & Notices

Privacy Policy Protected Health Information Non-Discrimination Policy Accessibility Statement Code of Ethics Pricing Clarity Customer Alerts Credit Card Billing Policy