Contract analysis

I. INTRODUCTION AND PURPOSE A. Purpose of the Code This Code of Business Conduct and Ethics (this "Code") sets forth the standards of ethical business conduct expected of all Covered Persons (as defined in Section I.B below) of Arbor Health Technologies Inc. ("Arbor Health," "AHT," or the "Company"), a corporation organized and existing under the laws of the State of Delaware. The Code is designed to promote honest a

II. CONFLICTS OF INTEREST A. Definition. A conflict of interest exists when a Covered Person's private interest interferes, or reasonably appears to interfere, with the interests of the Company as a whole. A conflict of interest can arise whenever a Covered Person takes action or has an interest that may make it difficult for the Covered Person to perform his or her duties and responsibilities to the Company objectiv

III. CONFIDENTIALITY AND PROTECTION OF COMPANY INFORMATION A. Confidential Information Covered Persons have an obligation to protect all confidential information of the Company. During the course of their employment or service, Covered Persons will have access to a wide range of confidential and proprietary information that is critical to the Company's competitive position and business success. "Confidential informat

IV. INSIDER TRADING AND SECURITIES LAW COMPLIANCE A. Prohibition on Insider Trading Federal securities laws, including Section 10(b) of the Exchange Act and Rule 10b-5 promulgated thereunder, prohibit the purchase or sale of securities while in possession of material non-public information ("MNPI") about the issuer of those securities. These laws also prohibit the communication (or "tipping") of MNPI to any person wh

Section 16 insiders are also subject to the "short-swing profit" recovery provisions of Section 16(b) of the Exchange Act, which require the disgorgement to the Company of any profits realized from a purchase and sale, or sale and purchase, of Company equity securities within any six-month period. The General Counsel's office will assist Section 16 insiders with their filing obligations, including the preparation and

V. FAIR DEALING AND HONEST BUSINESS PRACTICES A. Fair Dealing Covered Persons must deal honestly, fairly, and in good faith with the Company's customers, suppliers, competitors, employees, and business partners. The Company's long-term success depends on its reputation for integrity in all of its dealings. Covered Persons must not take unfair advantage of anyone through manipulation, concealment, abuse of privileged

VI. ANTI-CORRUPTION AND ANTI-BRIBERY A. U.S. Foreign Corrupt Practices Act (FCPA) and Domestic Anti-Bribery Laws The Company strictly prohibits bribery and corruption in all of its business activities. No Covered Person shall, directly or indirectly, offer, promise, authorize, or make any payment of money or anything of value to any government official, government employee, political party, party official, or candida

VII. PROTECTION AND PROPER USE OF COMPANY ASSETS A. Company Assets Covered Persons are entrusted with the care and protection of Company assets and are responsible for ensuring that those assets are used efficiently and for legitimate business purposes. Company assets include, but are not limited to: • Physical assets, including office space, furniture, equipment, computers, mobile devices, and supplies; • Technology

VIII. DATA PRIVACY AND CYBERSECURITY A. Privacy Obligations The Company is committed to protecting the privacy of personal information entrusted to it by patients, customers, employees, and other individuals whose data the Company collects, processes, stores, or transmits in the course of its business operations. The Company recognizes that the protection of personal information is not only a legal obligation but als

IX. EMPLOYMENT PRACTICES AND WORKPLACE CONDUCT A. Equal Employment Opportunity and Non-Discrimination Arbor Health is committed to providing equal employment opportunities to all employees and applicants for employment without regard to race, color, religion, sex (including pregnancy, childbirth, and related medical conditions), national origin, age, disability, sexual orientation, gender identity, gender expression,

X. POLITICAL ACTIVITIES AND LOBBYING A. Personal Political Activities The Company respects the right of its Covered Persons to participate in the political process in their personal capacities. Covered Persons may engage in personal political activities on their own time and at their own expense, including making personal political contributions, volunteering for political campaigns, and expressing personal political