Company Escalation & Reporting Policy

Original Date of Policy: January 2019
Entity: Health and Wellness Professionals Inc. (HWP)
Last Revision Date: February 2019

Introduction
Health and Wellness Professionals Inc.’s Code of Conduct, Employee Manual (collectively “HWP Policies”) comprise the framework under which HWP and its associates (“Associates”) conduct business. Associates are responsible to comply with the terms and spirit of these HWP Policies, to report incidents or violations and to participate in any subsequent reviews deemed necessary.

Policy Statement
HWP has created this Escalation Policy (“Policy”) to assist Associates with their reporting requirements and to ensure proper evaluation and escalation of identified incidents or violations. For external or internal incidents or violations that are not contemplated by existing policy, procedure or guidance, HWP Compliance Director(s) and HR have been charged with the responsibility of addressing these other issues. Upon an issue being reported, HR and the compliance directors will perform a brief assessment to determine the appropriate channel and resources for further evaluation, management and remediation. Once that determination has been made, HR and the compliance directors will coordinate remediation of the issue, with all relevant information, to the appropriate parties. Issues escalated according to this Policy will be treated as sensitive and will be discussed on a need-to-know basis with management and Legal, as appropriate.

Procedures
Requirements:
If an Associate is unsure as to how to best escalate a particular incident or violation, the Associate should:
• Contact HWP Compliance Directors (Cassandra Pinyan or Amy Adams) by:
o HWP Main Office Phone: (727)669-4551
o HWP Emergency Wellness Phone: (727) 483-0760
o Send email to: cpinyan@solutionsforyourwellness.com
o Send email to: aadams@solutionsforyourwellness.com
• If not response in reasonable timeframe (24 hours) contact HWP Executive Management by:
o HWP Main Office Phone: (727)669-4551 request to speak with Ann Owen
o Send email to: aowen@solutionsforyourwellness.com
o Send email to: towen@solutionsforyourwellness.com

HWP Compliance Director(s), in turn, is responsible for escalating issues reported which are beyond
The scope of their responsibilities and/or expertise or have potential firm-wide implications, to HWP
Executive Management. HWP Compliance Director(s) are also responsible for informing their
management of issues that other Associates may raise.

Associates may exercise their rights to directly contact any regulatory authority, government agency or
entity, to report possible violations of law or make other disclosures under applicable whistleblower
laws. Nothing in this policy is intended or should not be construed to restrict, discourage or interfere
with communications or actions protected or required by state or federal laws or regulations. Associates
do not need prior authorization of HWP or their management to make any such reports or disclosures
and will not be retaliated against for making such reports or disclosures.

Conflict Resolution and Escalation Process

Associates should immediately report any issues they believe are a potential or actual breach of this
Policy to HWP Compliance Directors or HWP Executive Management. The HWP Compliance Directors
or designee will review the matter and determine whether the issue is an actual breach and whether to
grant an exception, and/or the appropriate course of action. When making such determination, the
HWP Compliance Directors may, as part of his/her review, discuss the matter with relevant executive
management, HWP Wellness Director, or other parties (i.e. legal counsel, etc). The HWP Compliance
Directors can grant exceptions to any provision of this Policy so long as such exceptions are consistent
with the purpose of the Policy and applicable law, are documented and such documentation is retained
for the required retention period. Any questions regarding the applicability of this Policy should be
directed to the HWP Compliance Directors.