Matria Healthcare, Inc. (“Matria”) shall maintain a toll-free Compliance Hotline so as to provide all employees with an anonymous means of communicating concerns regarding possible violations of the Code of Conduct or Company Compliance and Ethics Plan.

POLICY SCOPE

This policy applies to Matria Healthcare, Inc., and its wholly owned subsidiaries, but does not necessarily apply to other entities in which a partial ownership interest exists unless otherwise agreed to by Matria.

PROCEDURE

Matria’s toll-free Compliance Hotline will be available to all Matria employees on a twenty-four (24) hour/day, seven (7) day/week, and 365 day/year basis.
Pursuant to a contractual agreement, a third-party vendor will provide, maintain and operate the Compliance Hotline for Matria employees.
The telephone number of the Compliance Hotline will be publicized in the Matria Outlook e-Directory, Matria’s InfoNet, and, as appropriate, on work area posters.
The Compliance Hotline will not identify the source from which the call originates so that the employee may remain anonymous if s/he so chooses. However, all Matria employees accessing the Compliance Hotline will be encouraged to provide their name and contact information so that the investigator may contact them with any follow-up questions. All Compliance Hotline cases will be handled in a manner that protects the privacy of the employee to the greatest extent practicable.
Employees will be encouraged to report problems, concerns, and potential violations of same without the fear of retaliation or reprisal.
All Matria employees accessing the Compliance Hotline will be asked to assign a password to his/her report. This password will enable the employee to access any updates or outcomes provided by the Corporate Compliance Officer (“Compliance Officer”) or designee in response to the employee’s report.
All information provided by the employee will be relayed immediately upon call cessation from the vendor to the Compliance Officer. All call transcripts concerning financial or accounting issues will also be sent to the Chairman of Matria’s Audit Committee of the Board of Directors.
The Compliance Officer shall designate an individual to record all calls received on the Compliance Hotline onto a Compliance Issues Log.
If the employee has a suggestion or general inquiry unrelated to a violation of the Code of Conduct or Compliance and Ethics Plan, the information shall be referred to the appropriate staff member and an annotation reflecting the referral shall be made in the Compliance Issues Log. For these types of calls, a case file will not be created. If the call is related to a potential violation of the Code of Conduct or Compliance and Ethics Plan, a case file shall be prepared with a copy of the transcription. The case file shall be referred to the Compliance Officer for handling in accordance with Matria’s policies on investigation and handling of Code of Conduct and Compliance and Ethics Plan violations and concerns (See Policy – Disciplinary Procedures for Non-Compliance). Notwithstanding the foregoing, if the call involves the conduct of the Compliance Officer, the case file shall be referred to the General Counsel for handling.
For cases with identified employees, the Compliance Officer or General Counsel, as the case may be, shall cause the employee to be contacted within five (5) business days of receipt of the call. The employee will be provided with the name and number of the person to contact for future inquiries.
This policy and procedure will be documented and retained for a period of at least six (6) years from the date of its creation or the date when it last was in effect, whichever is later.
Knowledge of a violation or potential violation of this policy must be reported directly to the Compliance Officer, or to Matria’s Compliance Hotline.