• We should educate our employees and stakeholders on the laws and regulations that affect their role at Capella
  
  
• We should ensure we are doing everything we can to comply with the laws and regulations that apply to Capella, and
  
  
• We promote a culture of personal integrity, based on the premises that honest mistakes will be made and we will learn from our mistakes. Employees and stakeholders are encouraged to come forward with honest mistakes and will not be punished for making them.
  

The educational component of our Ethics and Compliance program encourages every employee or stakeholder to seek information about his or her role at Capella. To that end, we have a policy that allows employees to direct questions directly to our Office of Ethics & Compliance. It is the responsibility of the Office of Ethics & Compliance to receive answers to those questions and report back to the employee.

At Capella, we do not proctor exams or review every work product of our employees. Our Code of Conduct requires our employees to conduct their jobs with honor and integrity. The Code of Conduct also requires our employees to report instances of misconduct. As is the case in many institutions that have a Code of Conduct, the failure to report misconduct is considered just as serious as the misconduct itself.

Capella's Ethics and Compliance Policies and Procedures (E&C Policies) are comprehensive. We have 145 detailed policies which address areas of hospital legal and regulatory compliance. The annual Code of Conduct is based on an abstract of those policies.

The E&C Policies are provided to Capella hospital Ethics and Compliance Officers for notice and distribution within each facility. They are posted on the Company's intranet as well as the Company's external website. Individuals within a facility who have responsibility for a particular area of compliance risk addressed by policy are responsible for implementing relevant policies, conducting necessary monitoring and overseeing corrective action or process improvements.

Capella maintains an Ethics Line to report items of concern or violations of policy. Although we encourage our associates to work with the local Ethics & Compliance Officers on matters of concern, the Ethics Line is an option to ensure such matters are identified and acted upon in a timely and effective manner. The Ethics Line can also be used to pose questions or receive clarification of certain laws and regulations.
You can also use the following contact information to contact the Capella Office of Ethics & Compliance:

Office of Ethics & Compliance
Capella Healthcare, Inc.
Attention, Eugene A. Fay, Ethics and Compliance Officer
501 Corporate Centre Drive, Suite 200
Franklin, Tennessee 37067

Phone: 615/764-3007
Fax: 615/764-3038