Code of Conduct

Last Revised: January 2026  |  Previous revisions: 11/2022, 4/2023, 2/2024, 3/2025

Who We Are

In the ever-changing, dynamic environment of healthcare we prioritize patient care and service-based relationships above all else — amongst our staff, our clients, and for all of the patients we serve.

We are an employer of choice for those entering the profession and we retain happy, balanced, patient-oriented team players who thrive in a collaborative culture while feeling valued and supported through excellent compensation and benefits.

We have the space needed to promote collaboration, sustain growth, and to enhance development and operations that support and foster financial sustainability and continued success.

We invest in technology and continually improve our state-of-the-art processes to enforce and enhance our reputation for providing premier pathology services.

Message from the CEO

The Code of Conduct clarifies our ethical and behavioral expectations for all employees of Summit Pathology. It provides critical guideposts for ensuring that our daily actions and interactions are in line with the mission and vision we have defined and adopted as an organization.

According to the Ethics and Compliance Initiative: “A well-written code of conduct clarifies an organization’s mission, values and principles, linking them with standards of professional conduct. The code articulates the values the organization wishes to foster in leaders and employees and, in doing so, defines desired behavior. As a result, written codes of conduct or ethics can become benchmarks against which individual and organizational performance can be measured.”

As an employee of Summit Pathology, it is critical that you read, fully understand, and adhere to this Code of Conduct. If you have questions or concerns, please reach out to the Director of Compliance at Summit Pathology.

The work that you do each day at Summit Pathology is critical to our ability to deliver the highest quality of pathology services as we support physicians and patients who depend on the diagnostic testing we provide. The code of conduct helps remove any mystery from the ethical stance we have made as an organization.

Put simply, integrity is knowing what is right and doing what is right — as individuals and as an organization. Please join me in doing what is right so that Summit Pathology continues to function with the highest level of integrity.

Jeff Christinson, CEO

What Is a Code of Conduct?

The Code of Conduct is intended to: 1) prevent wrongdoing, 2) encourage ethical conduct, 3) ensure compliance with all applicable state and federal laws, rules, and regulations, and 4) adopt a fair, accurate, and timely disclosure of compliance concerns or violations.

Ethics — Summit Pathology holds itself to the highest ethical standards and expects all employees, including management, pathologists, contractors, and vendors to do the same.

Integrity — Summit Pathology is dedicated to uncompromising integrity in all areas of the workplace. This includes our commitment to the integrity of our employees and our relationship with our customers and vendors.

Everyone at Summit Pathology is required to adhere to this Code and promote an environment of ethics, integrity, and compliance.

When an employee observes activity or behavior that appears unethical or improper, it is imperative that the employee voice their concerns directly with the Compliance Officer or leave a detailed message on the Compliance Hotline. The employee will be met with a guarantee of fair treatment and without fear of retribution or retaliation.

This Code is intended as a guide to overall ethics and conduct within the workplace. It is not a substitute for the Compliance Program established at Summit Pathology SP/SPL.

Each employee is obligated to read, understand, follow, and acknowledge all compliance associated policies and procedures. Employees who knowingly and willfully violate these standards will be subject to disciplinary action, up to and including termination of employment.

Anonymous Helpline: 833-836-6812

Business Conduct

Summit Pathology conducts business operations with integrity as evidenced by fair, honest, and ethical behavior. It is the desire of Summit Pathology to engage in ethical and legal business practices. The purpose of business entertainment is to create long-standing relationships with our customers, including physicians, physician practices, hospitals and their employees, patients, vendors, and contractors.

Gifts and entertainment may never be solicited or accepted by any pathologist, officer, or employee (or any family member thereof) unless it: 1) is not a cash gift, 2) maintains consistency with business practices, 3) is not excessive in value, and 4) meets allowable federal guidelines and standards. Any offering of gifts or proposed gifts must be discussed directly with the Compliance Officer.

Pathologists, officers, or employees may not provide gifts, loans, or other benefits to a current or potential customer. Allowable gifts are appropriate only when: 1) the gift is occasional, 2) the value is modest, 3) the value is part of an educational or marketing activity, and 4) the value or benefit does not violate any state or federal law. Gifts may only be in the form of items or services — not cash or cash equivalents — and must not exceed the aggregate of total allowable expenditures per year, per physician.

Conflict of Interest

Any perception of a conflict of interest must be avoided at all times. Pathologists and employees must avoid engaging in any actions that may influence their judgment or impartiality. A conflict of interest may include working for a competitor, vendor, or other healthcare provider.

Accepting gifts, payments, or services from individuals, groups, or vendors that do business with Summit Pathology is prohibited. Owning or having a financial relationship or financial interest with a competitor is prohibited.

Employees may hold a second job provided it does not directly or indirectly compete with Summit Pathology SP/SPL, does not require use of Summit Pathology assets or confidential information, does not affect the employee’s ability to properly perform their job, does not conflict with the employee’s work schedule, and does not negatively affect the image or community standing of Summit Pathology SP/SPL.

Confidentiality

Summit Pathology strives to maintain the trust of physicians, patients, and the community we serve. Confidential information entrusted to Summit Pathology must be maintained at all times. All employees, pathologists, consultants, and vendors must never disclose confidential information to anyone unless required by law.

Confidential information must be protected against theft, loss, or inappropriate disclosure. This may include electronic protected health information (ePHI), financial information, and policies. Any Summit Pathology proprietary information may only be used for company purposes and disclosed only to authorized personnel. Documents containing proprietary information may not be copied, released, or removed from the premises without prior authorization.

Summit Pathology is committed to honoring patients’ expectations of privacy. Summit Pathology will follow state and federal law with regard to privacy and confidentiality of patient data in accordance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Personnel should never discuss a patient’s test results or provide information about a patient unless authorized on a “need to know” basis.

Employees may not post on social networking sites or blogs any sensitive, proprietary, or confidential information about the company or any Protected Health Information (PHI). Communicating confidential information is grounds for termination of employment. Employees should report any violations of patient confidentiality policies directly to the Compliance Officer.

Billing / Arrangements with Physicians

Summit Pathology will bill only for services rendered, and all billing must comply with federally funded requirements. Each claim submission must be accurate, contain appropriate codes reflecting only services performed, and be well documented. Our billing services will correct billing errors and provide timely refunds as appropriate. Providing inaccurate reporting may expose the company and employee to civil and criminal penalties, as well as possible termination of employment or contract.

In order to comply with Fraud and Abuse laws governing Medicare, Medicaid (CMS), and other federal health programs, payment of remuneration in return for the referral of Medicare and Medicaid patients is strictly prohibited. Making false claims to Medicare and Medicaid is also strictly prohibited. No employee may offer any benefit to a referring physician with the condition that the physician or physician group will refer specimens to Summit Pathology. Any agreement involving compensation or referrals with a physician or physician group must be approved by legal counsel prior to execution.

Protection of Company Assets and Proprietary Information

Employees should protect all Summit Pathology data and property against loss, theft, and misuse. Information must be kept confidential and must not be made available to unauthorized persons. Each employee must also protect intellectual property, including scientific and technical knowledge and any activities related to production, marketing, sales, and finance.

Information related to Summit Pathology and its associates is highly confidential and may not be disclosed to anyone outside of the organization. If an employee becomes aware that proprietary information has been lost, compromised, or misused, they must immediately contact the Chief Compliance Officer so that an investigation may be pursued and action taken to protect the company.

Working Environment / Safety

Sexual Harassment

No employee of Summit Pathology shall engage in any conduct that may be construed as sexual harassment as established by the Equal Employment Opportunity Commission and by company policy.

Discrimination

Summit Pathology will not tolerate any illegal discrimination, harassment, or retaliation of any kind. Violence or intimidating behavior will not be permitted. Any disparaging comments based on race, ethnic origin, sexual orientation, or unwanted sexual advances will be grounds for investigation and may result in termination of employment.

Drug-Free Work Environment

Summit Pathology prohibits employees from possessing, using, distributing, purchasing, or selling illegal substances during scheduled work time or any time while conducting laboratory business. Alcohol abuse will not be tolerated during work hours. Reporting to work under the influence of controlled substances or alcohol is strictly prohibited.

Summit Pathology takes laboratory safety very seriously. Employees should report any concerns or violations to their immediate supervisor, manager, or the Compliance Officer.

Safety

Summit Pathology is responsible for maintaining a safe work environment. Employees must comply with all local, state, and federal laws and regulations, including the rules and regulations of the Occupational Safety and Health Administration (OSHA).

Compliance Committee

Report concerns online at summitpathology.ethicspoint.com or summitpathologymobile.ethicspoint.com.

Anonymous Helpline: 833-836-6812