Operating with integrity

President and Chief Executive Officer Byron Jobe leads the Vizient team from our Irving, Texas, headquarters. With a strong background in finance and deep knowledge of health care, Jobe has a long history of leadership roles within Vizient and in the industry, specifically in the areas of strategy, operations and finance.

A coordinated communications program ensures that members, customers, suppliers, employees and other key stakeholders are well-informed of news and information pertaining to financial performance.Consolidated Financial Statement – As part of our commitment to operational transparency, stockholder member CEOs and CFOs can view the company's financial statements.Value reporting – Each spring, we produce customized Value Scorecards for members to show the benefits earned through network participation.

The Vizient Board of Directors ensures the integrity of financial audits and reports to member organizations through our Audit and Finance Committee, which oversees financial reporting, investment portfolios (including corporate, 401(k) and pension), internal audit and risk and insurance programs.

The Governance Nominating and Compliance Committee oversees the implementation of our compliance program, including our Standards of Business Conduct and policy on conflicts of interest. The Compliance Officer presents status reports and issues at committee meetings. The Compliance Officer is a resource for any person in the organization who has a concern about ethical conduct. Additionally, a toll-free compliance line is available, (800) 750-4972. To encourage anyone to report possible conflicts of interest or other compliance-related issues, callers can report their concerns anonymously.

We are committed to maintaining the highest standards of ethics and openness in everything we do. To maintain a transparent organization, we share information through an integrated system of communications. Our Standards of Business Conduct convey our expectation that employees demonstrate ethical practices and ensure we comply with legal and contractual requirements, prudent financial practices, and related corporate policies and procedures. Related, our Conflict of Interest Policy further preserves and protects the integrity of all decisions made, making certain the interests of Vizient, not the individual, prevail.

Employee commitment to compliance is an essential component of our core business practices. We have developed a comprehensive Business Conduct, Compliance and Ethics Program. The Standards of Business Conduct serve as the foundation for our program, which is supported by our Board of Directors and management.

The program reflects the principles outlined in the Standards of Business Conduct, the Code of Conduct adopted by the Healthcare Supply Chain Association (HSCA), the Healthcare Group Purchasing Industry Initiative (HGPII), and other related industry and governmental compliance guidance and applicable law.

Led by the Compliance Officer, the Compliance team works with senior management to ensure Vizient's compliance with the program. Oversight and direction are provided by the Vizient Board of Directors and its Governance Nominating and Compliance Committee. The program includes the key elements outlined by the Federal Sentencing Guidelines:

• Standards, policies and procedures
• Governance and oversight
• Confidential procedure for asking questions and investigating compliance concerns
• Compliance hotline and website for asking questions and reporting compliance concerns
• Ongoing monitoring and auditing
• Education and training

Vizient's Standards of Business Conduct go above and beyond what the law requires. Our Standards reinforce our commitment to abide by all applicable laws and regulations, and they provide employees guidance in identifying and handling a variety of potentially challenging compliance issues and concerns. These Standards cannot anticipate every situation that employees may face. However, no concern is too small or unimportant if it implicates Vizient’s conduct in the market and reputation. To promote confidence in the services provided to members, we expect all employees to maintain the highest standards of loyalty and ethical principles.

Our Standards of Business Conduct:

• Clearly define Vizient’s values and principles
• Introduce some of the laws and regulations our employees must follow
• Set clear expectations of our employees and the part each plays in fulfilling these values and principles
• Give employees guidance on how to make the right decisions, consistent with our Standards
• Identify resources to use in reporting concerns as well as guidance through our non-retaliation policy

At Vizient, we expect our contracted and prospective suppliers to comply with the spirit of these Supplier Standards as well as all applicable laws and regulations, in all facets of their business relationship with us and with members.

In addition, suppliers are expected to:

• Execute a supplier certification form acknowledging their receipt and understanding of these Standards.
• Refrain from giving, offering, accepting or soliciting anything that can be construed as a bribe, kickback or other illegal or unethical payment with respect to business arrangements between Vizient and the supplier.
• Comply with Vizient’s gifts, business meals and entertainment policies in their dealings with our employees.
• Honor the terms, conditions and spirit of all agreements with Vizient and members.
• Maintain the confidentiality of Vizient’s and members’ confidential information, including but not limited to contract terms and supply chain data.
• Honor the intellectual property rights of our company and members, and refrain from infringing upon any of their respective trademark, service mark, copyright or other intellectual property rights.
• Submit timely and accurate reports regarding transactions with Vizient and members, including sales and administrative fee reports.

These supplier expectations should not be considered exclusive. At Vizient, we expect our contracted suppliers to conduct themselves with the highest business integrity and ethics in dealings with both us and members.

To ensure that contracted and prospective suppliers have the ability to voice concerns regarding our contracting process, we have a Vendor Grievance Policy. Additionally, our Legal and Compliance Departments are available to address supplier questions and concerns.

To preserve and protect the integrity and independence of all decisions affecting Vizient, employees must avoid situations in which their personal activities and/or relationships could create, or appear to create, a conflict of interest. A conflict of interest occurs when it becomes difficult to objectively carry out job responsibilities or act in the best interest of Vizient. All officers and employees of Vizient must maintain the highest standards of business conduct and ethical principles.

It is not practical to describe every situation that might raise a conflict of interest or the appearance of one. However, specific guidelines and examples of conflict situations are outlined in our Conflicts of Interest policy, which is accessible through our intranet or by contacting a member of our Compliance team. If an employee thinks a conflict of interest situation may exist, the employee should disclose the potential conflict of interest situation to a supervisor and/or a member of the Compliance or Legal teams.

General guidelines

Employees should use sound judgment and exercise reasonable business discretion in all business interactions. Employees who are, or potentially may be, involved in a conflict of interest should discuss and disclose such situations with a supervisor and/or the Compliance and Legal teams.

Topics covered under the Conflicts of Interest Policy include:

• Individual equity interests
• Property or service transactions
• Gifts, meals and entertainment
• Confidential and proprietary information
• Personal relationships
• Employment or consulting relationships
• Serving as an officer or member of a board of directors outside of Vizient
• Political contributions and unethical payments
• Lobbying and other contacts with government officials
• Honorariums

Disclosure obligations

Employees are required to complete a Conflicts of Interest Disclosure form within the first 30 days of employment.

All employees are required to complete a conflicts of interest disclosure form at least annually and as actual or potential conflicts arise.

Investigation of complaints

Vizient is committed to thoroughly investigating every compliance or ethics inquiry and complaint. Based on the merits and, depending on the results of the investigation, appropriate action will be taken. Confidentiality obligations may prevent our Compliance department from sharing the results of the investigation, and in most instances, the name of the individual who initiated the complaint. However, please know that we take every complaint seriously and will do our best to keep appropriate parties informed.

Non-retaliation

Vizient strictly prohibits harassment of, or retaliation against, any employee or person who, in good faith, reports a known or suspected violation of the law, our Standards of Business Conduct or company policies and procedures.

Subject to our obligations under applicable laws and regulations and our need to investigate the issue, we take every step possible to ensure the confidentiality of the individual reporting. Although coming forward will not immunize an individual from the consequences of his or her own misconduct, the individual’s good-faith reporting of an incident will be protected.

Procedures for raising issues

Employees, members, suppliers and other interested parties may submit concerns through (1) our compliance hotline website, vizientinc.ethicspoint.com, or (2) our toll-free compliance hotline, (800) 750-4972. Both are available 24 hours a day, seven days a week. To ensure that individuals are not discouraged from filing a report, all reports remain confidential to the maximum extent possible, with the option to remain anonymous. To ensure confidentiality in reporting, all reports filed through the hotline are managed by a third-party vendor and forwarded to our compliance department for review and investigation.

Vizient’s HIPAA Compliance Program addresses issues concerning the privacy and security of health information mandated in the Health Insurance Portability and Accountability Act of 1996, as amended by the Health Information Technology for Economic and Clinical Health Act of 2009 (“HITECH”) and Omnibus Rule (collectively defined as “HIPAA”).

We recognize the importance of privacy, confidentiality, integrity, availability and security of individually identifiable health information, referred to as Protected Health Information (“PHI”) under HIPAA. In support of serving our members and complying with the HIPAA Security and Privacy Rules, we have invested heavily in administrative, physical and technical safeguards to support reliable and highly secured operations.

Questions regarding Vizient’s HIPAA and HITECH Act compliance should be directed to the privacy team at privacy@vizientinc.com.

Vizient does not manufacture, label, package, repackage, maintain, inventory, sell, distribute or control specifications for any product. All such activities are the sole responsibility of the product’s manufacturer, distributor or other seller. To ensure unmatched quality and value to members, we have implemented a quality program to select and monitor suppliers effectively, and as appropriate, to ensure timely and proactive communication to members.

Because selection of products by members is voluntary, we select suppliers we believe will provide safe, efficacious, readily available and cost-effective products for use by our members. Further, at Vizient, we are committed to monitoring suppliers’ quality and regulatory performance, monitoring overall industry standards and, as appropriate, proactively notifying members of any material quality or regulatory issues or trends.

Quality policy

We strive to provide members with a unique competitive advantage in the marketplace via access to anesthesia, medical, pharmaceutical, radiology, respiratory, surgical, and other health care and non-health care products with unmatched quality, value and efficiency.

Quality program

One of our top priorities is to select and promote manufacturers that will provide safe, effective, readily available and cost-effective products for use by member institutions. To help ensure all products meet the high expectations of our members, the following quality program is in place:

• Supplier selection and approval – Vizient carefully selects and approves suppliers based on member direction and other predetermined criteria. We strive to select only products that meet the highest quality and safety standards. On our members’ behalf, we conduct a targeted review prior to the selection of any supplier.
• Monitoring of suppliers – Vizient’s quality assurance and regulatory affairs personnel monitor supplier’s quality and regulatory performance throughout the contract period to facilitate any necessary actions or communications to members.
• Notification and communication to members – Vizient provides information regarding the safety or efficacy of products to members in a timely manner. For example, product recalls, shortages, consent decrees, customer complaint trends or other regulatory issues, result in member notifications.
• Liaison between members and suppliers – Upon request, Vizient will reasonably assist in resolving situations involving member complaints and safety concerns. In such cases, our Quality and Regulatory personnel will initiate the complaint with the supplier, evaluate the investigation details from the supplier, provide a close-out letter to the member, and review/trend complaints for business unit actions.
• NOVAPLUS® label differentiation – NOVAPLUS – Vizient’s private label brand of pharmacy, medical, surgical, food, and laboratory products and purchased services — is a key part of our comprehensive supply chain management strategy, offering high quality at the lowest market price on the most frequently purchased products and services. We are committed to coordinating with NOVAPLUS suppliers to minimize medication errors, product mix-ups, or misadministration due to similar-appearing labels. We ensure NOVAPLUS products are identical to the manufacturer-branded equivalents.

Questions regarding these activities should be directed to Pamela Anderson, Quality Assurance and Regulatory Affairs Director at (972) 581-5578 or pamela.anderson@vizientinc.com.