Notice of Privacy Practices
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED, AND HOW YOU CAN GET ACCESS TO THIS
INFORMATION. PLEASE REVIEW IT CAREFULLY.
Health & Wellness Professionals, Inc. is committed to protecting the confidentiality of its patient’s health information. We have policies and safeguards in place to ensure your privacy. Health & Wellness Professionals, Inc. is also required by state and federal laws to protect the confidentiality of your health information.

Health & Wellness Professionals is committed to maintaining and protecting the information you supply including all personal information, the results of biometric screening tests, the information in your health assessment risk profile, and other health data or information collected. HWP keeps your PHI (protected health information) safe using a combination of physical, electronic, and procedural safeguards in accordance with applicable Federal and State laws.

The confidential health information that we collect as we deliver care or services to you is called “protected health information”. We can use and disclose your protected health information:

To provide treatment and to help us coordinate services among Health & Wellness Professionals, Inc. personnel and with others involved in your
care such as family members, your pharmacist, suppliers of medical equipment and your physician; or we can use your information to recommend
an alternative treatment to you or to notify you of a service such as availability of flu shots.

To obtain payment such as including your health information on invoices to collect payment. For example, we may be required by your insurer to
provide information regarding your health so that they will pay you or Health & Wellness Professionals, Inc. We may also need to obtain prior
approval from your insurer and explain your need for home care and the care or services that we will provide to you.

For health care operations, such as using your protected health information to evaluate and improve the quality of the services or to write new
guidelines to provide more effective nursing care; to conduct supervision of employees or evaluate their performance; to train our employees or
student nurses; to determine your satisfaction with our services; for general business planning and development; or for business management and
general administrative activities.

Humana Go365 Members: The results of your screening today may contain Protected Health Information (PHI) and will only be shared with the
Go365 Program for the purposes of your program reward points. An aggregate report may be provided to your employer without any identifiable
PHI. If you have any questions about PHI and your privacy protection, please go to your Go365 Dashboard and view Humana’s Notice of Privacy
Practices.

United Healthcare Members: The results of your screening today may contain Protected Health Information (PHI) and will only be shared with
United Health Care via Optum. An aggregate report may be provided to your employer without any identifiable PHI. If you have any questions
about PHI and your privacy protection, please go to your member Dashboard and view United’s Notice of Privacy Practices.
You also have the following rights regarding the use and disclosure of your protected health information:

You can request that we restrict its use and disclosures-such as not sharing this information with a family member. However, we are not required
to agree with every restriction and we may end such a restriction if we believe it puts you or your health at risk. You can also decide to end a
restriction at any time.

You can request that communication between you and Health & Wellness Professionals, Inc. be provided to you in another way. For example, we
can send all our written communication to your daughter’s address, if you ask us to do so.

You can ask to inspect and copy your protected health information and you can request to change it.

You also have the right, with limited exceptions under federal regulations to receive an accounting of the disclosures we have made of your
protected health information other than those used for treatment, payment, or operations.

Health and Wellness Professional’s keeps participant records for a minimum of five years on a secure HIPAA compliant and SOC2 Certified cloud
server as well as at HIPAA compliant and SOC2 certified offsite facility.

If you believe that your confidentiality has been violated, you can contact our home office and speak to Cassandra Pinyan, our Director of
Operations through our Home Office at (727) 669-4551 to file a complaint or you can file a complaint with the office of the Secretary of Health and
Human Services. We want to hear your concerns, and you will not be retaliated against if you file a complaint.

If you wish to see your protected health information, receive a copy of it or ask to amend it, please contact our Home Office, (727) 669-4551. If
anyone wishes to use or access your protected health information for reasons other than to provide care, obtain payment or run our operations,
we can only release it with your written authorization. And, you may revoke that authorization at any time.

However, there are some important exceptions to requiring an authorization stated in the federal regulation. We can provide your protected
health information to representatives of the following organizations without your written authorization or without obtaining your agreement or
objection:

1) To public health authorities;
2) To a government representative responsible for responding to concerns about abuse, neglect or domestic violence as permitted by law;
3) For judicial or administrative proceedings or in response to a subpoena or discovery request;
4) For law enforcement purpose;
5) To local or national health oversight organizations that conduct audits or investigations;
6) To funeral directors, coroners and medical examiners;
7) For purposes of organ or tissue donation;
8) For research purposes as approved by a Privacy Board;
9) To avert a serious threat to health or safety; and for
10) For special government functions, such as national security; and,
11) For purposes of worker’s compensation.

We may not disclose your health information if you are the subject of an investigation unless your health information is directly related to your
receipt of public benefits.

We at Health & Wellness Professionals, Inc. abide by this Notice effective January 1, 2020. The Notice is available to any individual upon request.
We do reserve the right to change the terms of this Notice, and to provide the revised Notice to any patient/client who is receiving care or services.
Health & Wellness Professionals, Inc. reserves the right to change this Notice of Privacy Practices; and if we do so, the changes will apply with
respect to your protected health information in our possession.

If you have any concerns or concerns, please contact our home office at (727) 669-4551.

Whistleblower Policy- Clients

Health and Wellness Professionals, Inc. (herein known as HWP), aims to ensure that the delivery of a service to a
client/patient is always of the highest quality and that the client/patient feels satisfied with their experience at HWP.
Should a client/patient feel that the service they received did not meet their expectations, or that they are unsatisfied
with the service provided, all persons have the right to lodge a complaint.

HWP aims to respond to complaints in a transparent, open and efficient manner. We will provide a safe environment for
all clients, so they can feel able to make a complaint without fear of repercussions or that they will be negatively
impacted upon due to the complaint. HWP respects and promotes the right of individuals to express concerns or
problems and lodge complaints and ensure that there will be no negative consequences for any client who lodges a
complaint.

To make the process of lodging a complaint as seamless and possible, HWP has a Complaints Resolution Process in place.
All staff members must be able to describe this process should a client enquire about the process of making a complaint.
HWP will endeavour to resolve all complaints at a service level. However, if a client/patient feels that a satisfactory
outcome is unable to be reached at this level, the complaint can be directed to relevant external bodies for further
investigation, the details for which can be found listed at the conclusion of the procedure.
Additionally, client/patients have the option to remain anonymous if requested. Our service complies with relevant
privacy legislation when responding and handling complaints.

Procedure

6 Step Complaints Resolution Process
Our six step procedure for resolving complaints is as follows;

  1. Acknowledge
    A client, patient, community member or organization can make a complaint verbally in person, over the phone or in
    writing, or via our website. A person can speak to any staff member who will direct them appropriately, or they may call
    and ask to speak directly to any member of the Management Team or Director. Alternatively, a client may feel
    comfortable with a particular staff member and can choose to have them record their complaint.
    The client has the right to remain anonymous should they choose.
    The complaint is submitted to the Executive Management and will be acknowledged in writing within 7 working days of
    receiving the complaint through an ‘Acknowledgement of Complaint Letter.’ If the complaint is against the Management
    Board then this process must be followed through by a upper level staff member within seven days of the complaint
    being received.
  2. Assessment
    Within the same 7 days, the complaint will be assessed and assigned priority by the Executive Management based on
    the severity of the nature of the complaint.
    From this it will be decided whether the development of a plan is required detailing further investigation and action, or
    if the complaint can be resolved promptly. If the complaint can be resolved promptly, the complainant will be contacted
    and liaised with via a phone call or scheduled meeting with the person. All complainants will receive documentation
    stating their complaint and the resolution of the situation from a member of the Executive Management team.
  3. Plan
    If a complaint cannot be promptly resolved, a plan must be devised to detail the steps in addressing the complaint. The
    plan must outline what is to be investigated (the situation, problem or issue) and the steps involved in resolving the
    complaint. For example, more information may be needed, estimated time of resolving the complaint, identification of
    the action the complainant desires, as well as noting any special considerations, such as any sensitive information or
    confidentiality and privacy issues or requests. The purpose of the plan is to ensure that nothing is overlooked, and that
    investigation does not lose its focus.
  4. Investigate
    For a complaint to have a fair investigation there are three principals that should be followed at all times:
    • Impartiality – Taking an open-minded approach, considering the facts and objectively looking at the account
    of the complaint provided by the complainant.
    • Confidentiality – When identifying details of a complaint the investigation should be done privately and
    confidentially and care is to be taken when disclosing information to other relevant personnel.
    • Transparency – The complainant should have knowledge of the various steps involved in the Complaint
    Resolution Process and be given an opportunity for involvement and to comment or dismiss.
    It is equally important to note that HWP encourages the complainant to take an active and participatory role during the
    review of factors/issues related to the complaint and will support the person to be included in the process, so should
    they wish to be.
  5. Respond
    Once the complaint has been investigated the complainant is to be informed of the resolution. All complaints may not
    be able to reach a conclusion in the case that there is insufficient evidence to support the complaint. However, the
    details of this should be explained and discussed with the complainant, if the complaint was not anonymous. All effort
    will be put into reaching a satisfactory resolution for all involved parties. The complainant should be provided with
    details regarding about the process and how the conclusion was reached. This information will be communicated
    through the “Outcome of Complaint Letter” and if necessary, a meeting will be set up with the complainant.
  6. Follow Up
    Once the response letter has been sent out, time is given for the complainant to seek a review of how the complaint was
    resolved. HWP will always allow time to discuss outcomes of complaints and resolution processes with complainants.
    If you feel that the complaint has not been resolved or if you wish to take the complaint above HWP, you are able to file
    a complaint with the United States Department of Health & Human Services via the following link:
    https://www.hhs.gov/hipaa/filing-a-complaint/index.html

Whistleblower Protection Policy

This policy is designed to protect employees and address Health & Wellness Professionals, Inc. commitment to integrity
and ethical behavior. In accordance with Whistleblower Protection regulations, Health & Wellness Professionals, Inc. will
not tolerate harassment, retaliation, or any type of discrimination against an employee who:

  •  Makes a good faith complaint regarding suspected Company or employee violations of the law
  •  Makes a good faith complaint regarding accounting, internal accounting controls, or auditing matters that may lead to incorrect, or misrepresentations in, financial accounting.
  •  Provides information to assist in an investigation regarding violations of the law; or
  •  Files, testifies, or participates in a proceeding in relation to alleged violations of the law.
  •  Negative employment sanctions, such as demotion or termination, as a result of an employee’s decision to provide good-faith information regarding violations of the law, will not be tolerated. In addition, discrimination, threats, and harassment is prohibited. Anyone violating this policy will be subject to discipline, up to and including termination of employment.

Retaliation is defined as any adverse employment action against an employee, including, but not limited to, refusal to
hire, failure to promote, demotion, suspension, harassment, denial of training opportunities, termination, or
discrimination in any manner in the terms and conditions of employment.

Anyone found to have engaged in retaliation or in violation of law, policy or practice will be subject to discipline, up to
and including termination of employment. Employees who knowingly make a false report of a violation will be
subject to disciplinary action, up to and including termination.


Anonymous Reporting Form

Company Escalation & Reporting Policy

Original Date of Policy: January 2019
Entity: Health and Wellness Professionals Inc. (HWP)
Last Revision Date: January 2020

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.

Event and Staff Complaint Reporting Procedure

Original Date of Policy: January 2017
Entity: Health and Wellness Professionals Inc. (HWP)
Last Revision Date: January 2020

Introduction Health and Wellness Professionals Inc.’s (HWP) goal is to collaborate with our biometric wellness clients to create, schedule and deliver a corporate biometric screening event in support of your company’s overall wellness program. We handle everything from start to finish so you can concentrate on what you do best: running your company. During the biometric event scheduling meetings HWP listens to your requests and any concerns to tailor a biometric wellness event that will engage and encourage your employees to participate while meeting your company’s needs. Our participant care is of the upmost importance to us, in fact it’s at the center of our core values. If clients have issues or concerns with your current or completed biometric wellness event, the wellness staff or the quality of participant care, we want to hear about it immediately.

Policy Statement

The Event and Staff Complaint Reporting Procedure outlines the steps to follow if you have any issues or concerns relating to your current or completed biometric wellness event, HWP staff members or quality of participant care during the event. This policy applies for all HWP biometric events and staff members assigned to deliver service at biometric wellness events.

Event and Staff Complaint Reporting Procedure Supporting our core values with a emphasis on excellence, Health and Wellness Professionals Inc. expects all corporate biometric wellness events to be carried out with professionalism and safety and Health and Wellness Professional Inc.’s staff members to perform their screening functions with utmost professionals, participant care and compliance to HIPAA regulations for Patient Health Information (PHI) in accordance with Health and Wellness Professionals Inc.’s Employee manual and Code of Ethics. HWP expects our corporate and wellness screening staff to help HWP maintain its excellent reputation by adhering to the high standards. As part of our culture of openness and accountability, we encourage all clients to report any incidents, situations, concerns and complaints where it is evident that the biometric wellness event and/or staff execution falls short of client expectations and Health and Wellness Professionals Inc.’s standards and values.

In order to assist in the reporting of concerns, HWP has established dedicated channels through which clients may file and/or voice concerns. All concerns and complaints raised in accordance with HWP procedures and will be treated promptly and in strict confidentially and with the complete assurance that there will be no retaliation against any client filing a complaint or raising a concern.

The Event and Staff Complaint Reporting Procedure

The Event and Staff Compliant Reporting Procedure outlines the steps to follow if clients have concerns and/or evidence of any serious issues related to HWP Biometric Wellness events or staff.

This includes, but is not limited to serious cases of the following:

● breaches of HWP Biometric Wellness event procedures and policy

● breaches of potential HIPAA policies or regulations

● breaches of HWP Corporate policies or procedures

● HWP personnel misconduct, disrespectful or unethical behavior

The Health and Wellness Professionals Inc’s Wellness Director has overall responsibility for the Event and Staff Complaint Reporting Procedure and its application. Clients are encouraged, should there be concerns or complaints to submit reports through the HWP reporting process, which consists of a telephone hotline, accessible 24 hours per day and direct email. Reports received through the HWP reporting process are received by HWP’s Wellness Director. As standard, a copy of emails are also sent to HWP Executive Management Team. The HWP Wellness Director ensures that all reported cases are investigated and dealt with in a lawful and timely manner, and with full respect to the rights of all individuals involved.

Complainant can rest assured that prompt and appropriate corrective action will be taken when and as warranted in the investigation of the complaint and will be kept informed of the progress of the investigation and actions taken.

If a Complainant is not satisfied with the follow-up to a complaint and/or the outcome of an investigation, he/she can file a subsequent complaint directly to HWP Executive Management via the company main office line at (727)669-4551.

Complainant instructions & contact details

● During work hours (8:00 am – 5:00pm EST) or after hours the complainant can either dial or text HWP Emergency Telephone Number (727)483-0760. In case of a text message and no initial call by the complainant to the emergency number; complainant should provide as much detail for the complaint, call-back phone number and time available for call-back by HWP Wellness Director and/or Executive Management, if requested. In the unlikely event that your phone call is not answered please leave a voice message and provide as much detail regarding the complaint:

• Your name

• location and time of event

• detail of complaint

• call-back phone number

• time available for call-back by HWP Wellness Director.

● Should complainant desire to send online complaint, complainant can send an email direct to the HWP Wellness Director at the following email addresses:

• hr@solutionsforyourwellness.com

• cpinyan@solutionsforyourwellness.com

Please provide as much detail regarding the complaint:

• Your name or name of complainant

• Location and time of event

• Detail of complaint

• Call-back phone number if requesting call back

• Time available for call-back by HWP Wellness Director.

The Executive Management team, after consultation with the HWP Wellness Director, may amend this policy at any time in a manner consistent with the requirements of applicable laws and regulations.