GLOBAL CODE OF ETHICS AND CONDUCT

LAST APPROVED: April 30th, 2025

Introduction

HMS Vision Inc., including its subsidiaries (“HMS, We, Our”) is committed to upholding the highest standards of integrity, transparency, and ethical conduct in all aspects of our operations. This Global Code of Ethics and Conduct (“Code”) serves as a guiding framework for our directors, executives, employees, volunteers, contractors, and all other stakeholders, both internal and external, reflecting our unwavering dedication to ethical behaviour and responsible decision-making. This Code embodies our core values and principles, guiding us in our interactions with each other and the broader community

By adhering to these ethical standards, we not only maintain the trust and confidence of those we serve but also uphold the fundamental principles of accountability, honesty, and respect that are integral to our mission and vision.

HMS Vision Inc. reserves the right to modify, suspend, or discontinue this website or any part of it at any time without notice or liability.

Our Core Values – TREAT

Transparency - We prioritize open communication, honesty, and accountability in all interactions, fostering a culture of trust and clarity.
Respect for All - We value diversity and treat everyone with dignity, fairness, and courtesy, creating an inclusive environment where all voices are heard and respected.
Empowerment and Ownership - We encourage autonomy and initiative, empowering individuals to take ownership of their work and drive positive change within our organization.
Accountability, Integrity, and Commitment - We uphold the highest standards of integrity, ethics, and professionalism, honouring our commitments and demonstrating unwavering dedication to our non-profit mission.
Teamwork - We recognize the power of collaboration, leveraging the diverse skills and the perspectives of our team members to achieve shared objectives.

1. Applicability

Ethical conduct is imperative at all times and across all sectors. This Code therefore serves as our ethical commitment and as a guide to proper conduct for all our stakeholders, including officers, directors, managers, contractors, consultants and any other person, businesses, and organisation that we engage with. Any breach of this Code or of any law or regulation must be reported to HMS’ management without delay in order to mitigate risk and maintain ethical conduct.

HMS strictly prohibits illegal or unethical behaviour. Any failure to meet ethical or legal requirements may result in termination of the relationship and where applicable, notification to relevant authorities.

This Code shall apply contractually wherever it has been expressly incorporated into agreements or contracts between HMS and any other party. Express incorporation of this Code will render it binding and enforceable upon the parties to the agreement or contract and subject to the terms of the contract.

The Board of Directors at HMS bear responsibility for demonstrating, through their actions, the importance of this Code, including investigating ethical questions raised, addressing any ethical concerns, conducting adequate risk assessments, where necessary, regularly reviewing, and updating existing controls and reporting legal and regulatory concerns to the appropriate authorities.

2. Legal and Regulatory Compliance

Through the delivery of technical consulting services and the deployment of training and technologies, we operate within highly regulated fields and across multiple jurisdictions. Therefore, legal, and regulatory compliance are critical to the success of HMS.

We affirm that we will not engage in any business practices or interactions with entities that seek to circumvent or undermine legal or regulatory requirements in any jurisdiction where we operate. Upholding ethical standards is integral to our organizational culture, and we expect all employees, contractors and all other stakeholders to adhere to the highest ethical principles in their dealings on behalf of or with HMS.

3. Bribery and Corruption

We recognize the detrimental impact that bribery and corruption can have on our mission and reputation as well as on society in general. Therefore, we are dedicated to strict compliance with anti-corruption laws and regulations across all jurisdictions in which we operate.

Definition of Bribery and Corruption

Bribery is generally defined as the offering, giving, receiving, or soliciting of anything of value to influence the actions of a foreign official in his or her official capacity. Corruption refers to the abuse of entrusted power for personal gain, which may involve bribery, fraud, extortion, or other unethical practices.

Compliance with Anti-corruption laws

HMS, in compliance with applicable law, prohibits the bribery of foreign officials for the purpose of obtaining or retaining business.

We will not work with or engage with any individuals, organizations, or entities that seek to induce any benefit from corrupt practices. We are committed to conducting our activities with integrity and will not compromise our ethical principles for any perceived gain. We will report any concerns in relation to corruption or bribery to the appropriate authorities.

To prevent bribery and corruption, we maintain adequate internal controls and procedures to ensure transparency, accountability, and compliance with anti-corruption laws and regulations. Additionally, we maintain record-keeping and books to accurately reflect all transactions and expenditures.

4. Transparency and Reporting Compliance

We are committed to transparency in our financial and other reporting requirements, in full compliance with the applicable laws.

HMS will prepare and maintain accurate records of its activities, including financial records, in accordance with generally accepted accounting principles (GAAP) and other relevant standards.

All financial and other reporting will comply with applicable laws, regulations, and industry standards. Any changes in reporting requirements will be promptly assessed and incorporated into our reporting processes.

Economic and financial decisions will be made on the basis of sound economic analysis, taking into account the organization's objectives and available resources. Decisions will be guided by principles of fiscal responsibility and sustainability.

5. Compliance With International Sanctions and Trade Restrictions

We are dedicated to abiding by all applicable laws and regulations governing international sanctions and trade restrictions. This unwavering commitment extends to adherence to sanctions lists provided by reputable bodies such as the United Nations Security Council (UNSC) sanctions list.

We pledge to meticulously screen and cross-reference all potential partners, contractors, and entities with applicable sanctions lists to ensure that our interactions remain lawful and ethically sound. Any entity found to be listed on an international sanctions’ lists will be immediately disqualified from engaging in any form of collaboration, transaction, or association with our organization.

Compliance with Trade Requirements

In conjunction with our dedication to sanctions compliance, HMS will also observe all relevant trade requirements and restrictions. This includes compliance with export controls, import regulations, and trade embargoes stipulated by pertinent authorities.

We believe that by diligently adhering to these laws and regulations, we not only uphold the integrity and reputation of our organization but also demonstrate our unwavering commitment to ethical conduct and responsible global citizenship. Any deviations from these standards will be promptly addressed and remedied to ensure continued compliance and ethical integrity.

6. Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT)

HMS is committed to upholding the highest standards of integrity and transparency in the prevention of money laundering and the financing of illicit activities across our operations. HMS will comply with all applicable laws and regulations in relation to anti-money laundering and terrorist financing. HMS will terminate any relation with entities that are involved in such illegal activities and will report any concern of such activities to relevant authorities. We expect our stakeholders to uphold the highest standards of diligence and compliance with such laws.

Risk-Based Customer Due Diligence

HMS conducts risk-based customer due diligence to assess the risk of potential money laundering activities associated with our contractors, donors, partners, and other counterparties. This includes obtaining and verifying customer identification information, assessing the nature and purpose of the relationship, and monitoring transactions for unusual or suspicious activity.

We are committed to promptly investigating and reporting any suspicious activity that may indicate money laundering or other illicit financial activities. Our staff members are trained to recognize red flags and escalate concerns to the designated Managers for further investigation and reporting as necessary.

Watchlist Screening

As part of our AML/CFT efforts, HMS performs watchlist screening to identify individuals and entities that may be involved in money laundering, terrorist financing, or other illicit activities. We utilize reputable screening databases to ensure compliance with regulatory requirements and mitigate the risk of engaging with sanctioned or high-risk individuals and entities.

HMS will not knowingly engage with entities that are engaged in money laundering, terrorist financing, or any other illegal activity. We remain vigilant in our efforts to uphold ethical standards and contribute to the prevention of financial crime in our immediate surroundings and beyond.

7. Employment Practices

HMS is committed to making employment decisions based solely on qualifications and merit, without discrimination or bias. We firmly believe in equal opportunity and do not discriminate on the basis of race, gender, sex, sexual orientation, gender identity, sexual expression, disability, veteran status, or any other characteristics protected by law.

We recognize and respect the fundamental human rights of all individuals. As such, we are dedicated to upholding and promoting human rights in all aspects of our operations. We pledge to comply with all relevant laws and regulations pertaining to freedom of association, privacy, collective bargaining, immigration, working time, wages, and hours.

Our organization condemns all forms of forced labour, including sex trafficking and child labour, and is committed to taking proactive measures to prevent and combat such exploitation. We maintain a zero-tolerance policy towards any form of employment discrimination, harassment, or abuse.

As part of our commitment to combating human trafficking and forced labour, our organization has implemented a comprehensive counter-trafficking in persons policy. This policy includes stringent controls and procedures aimed at ensuring that our organization does not engage with entities involved in any trafficking or labour-related infringements. We are dedicated to conducting thorough due diligence and implementing robust safeguards to protect against the exploitation of individuals in any form.

We expect all of our stakeholders to comply with the laws or regulations applicable to them in relation to employment practices and will terminate any relationship where we become aware of illegal activity or where our stakeholder falls short of these standards in relation to its employment practices.

8. Intellectual Property (IP)

Our organization is committed to protecting the intellectual property rights of both third parties and our own. We recognize that respecting and upholding IP rights is essential to fostering a culture of innovation and ensuring fair competition. Therefore, we pledge to:

Develop and manage our intellectual property rights with integrity and transparency, adhering to applicable laws, regulations, ethical principles and our organizational values.
Respect the intellectual property rights of third parties by obtaining proper authorization or licenses for the use of their IP, and by refraining from unauthorized use or infringement.
Safeguard our own intellectual property rights by implementing robust measures to prevent unauthorized use, disclosure, or misappropriation.
Educate our employees, partners, and stakeholders about the importance of intellectual property rights and their role in protecting and respecting these rights.
Encourage open communication and collaboration among stakeholders to foster innovation and responsible IP practices.

9. Cyber Security and Data Privacy

HMS is dedicated to maintaining the highest ethical standards in all aspects of our operations, including our data privacy practices and cybersecurity measures. We recognize the importance of safeguarding the privacy and security of sensitive information entrusted to us by our employees, customers, partners, and other stakeholders. As such, we have established comprehensive data privacy policies and cyber security measures in order to adequately govern our data privacy practices and cybersecurity efforts.

Data Privacy measures

We are committed to respecting the privacy rights of individuals and ensuring the confidentiality, integrity, and availability of their personal information.
We will collect, use, and process personal data only for legitimate business purposes and in accordance with applicable laws, regulations, and contractual obligations.
We will obtain proper consent from individuals before collecting or using their personal data, and we will provide clear and transparent information about our data processing practices.
We will implement appropriate technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, or destruction.
We will regularly review and update our data privacy policies and procedures to reflect changes in technology, business practices, and regulatory requirements.

Enhancement of Cybersecurity

We recognize the importance of maintaining a strong cybersecurity posture to protect our organization and stakeholders from cyber threats and attacks.
We will implement robust cybersecurity controls and measures to safeguard our information systems, networks, and data assets against unauthorized access, malware, and other cybersecurity risks.
We will continuously watch out for and report anomalies and other indicators of compromise (i.e. phishing emails or SMS messages with fake links).
We will never store or transmit passwords or credentials in plain text. We will only use company approved credential management systems for storage of passwords and other sensitive credentials.
We will not install new software and sign up for new online services unless previously approved by the Technology Operations department.
We will use Multi Factor Authentication (MFA) on all systems that support it.
We will regularly assess and monitor our cybersecurity posture through risk assessments, vulnerability scans, penetration testing, and other security measures.
We will provide cybersecurity awareness training and education to our employees, contractors, and other relevant stakeholders to promote a culture of cybersecurity awareness and vigilance.
We will establish incident response and recovery procedures to effectively respond to and mitigate cybersecurity incidents, breaches, and other security incidents.

HMS will comply with all applicable data privacy and security regulations across the various jurisdictions in which we engage. We expect our stakeholders to ensure adequate data privacy and security measures across their operations and particularly with respect to the information that is shared by HMS.

10. Conflicts of Interest

We recognize that conflicts of interest can arise in various situations and may compromise our ability to act in the best interests of our organization and stakeholders. HMS will address any established or perceived conflicts of interest to ensure that these do not negatively affect the ability of the organization to operate within legal and ethical bounds.

A conflict of interest occurs when an individual or entity has competing interests or loyalties that could potentially bias their judgment or decision-making in a way that could harm the organization's interests or impair their ability to fulfil its duties objectively and effectively.

Disclosure and Management of Conflicts of Interest

All employees, officers, directors, contractors, and volunteers, have a duty to promptly disclose any actual or potential conflicts of interest to HMS’ Management.
Upon disclosure of a conflict of interest, the individual or entity involved must provide full and transparent disclosure of the nature and extent of the conflict, including any relevant financial or personal interests, relationships, or affiliations.
We will evaluate the disclosed conflict of interest to determine its significance and potential impact on the organization's interests. Depending on the nature and severity of the conflict, appropriate measures may be taken to manage, mitigate, or eliminate the conflict. A conflict of interest is not in itself a breach of HMS’ Policy. HMS’ Management will decide on the basis of legal requirements and on the balance of risk, how to address the conflict.
In cases where a conflict of interest cannot be adequately managed or resolved, the individual or entity involved may be required to recuse themselves from the decision-making process or take other appropriate actions to avoid any perceived or actual conflicts.

11. Competition Compliance

Compliance with competition laws is essential for maintaining fair and open markets, promoting consumer welfare, and fostering healthy competition. Compliance with these laws helps prevent harmful practices such as price-fixing, bid-rigging, market allocation agreements, and monopolistic behaviour, which can distort markets, limit consumer choice, and harm economic efficiency.

HMS is committed to complying with all competition laws to promote market integrity and encourage innovation and efficiency, which are essential for the effectiveness of systems. HMS conducts thorough assessments of the market landscape and our engagements with parties within the markets to identify and mitigate any risks of non-compliance with competition laws. We will implement robust controls to ensure adherence to competition laws and uphold the principles of fair competition in all our activities.

We prohibit any form of anticompetitive behaviour, including price-fixing, bid-rigging, market allocation agreements, and other practices that restrict competition or harm consumers. Our organization will not engage in any conduct that violates antitrust laws or undermines fair competition.

We encourage employees and stakeholders to report any concerns or potential violations of antitrust laws promptly to HMS’ management.

12. Reporting Lines and Escalation Processes

Internal Reporting

Employees, contractors, volunteers and other internal stakeholders acting on behalf of HMS are encouraged to report any suspected violations of this Code or any other unethical behavior not expressly mentioned in this Code to their Manager directly.

External Reporters

Vendors, contractors and other external stakeholders who become aware of potential or actual ethical violations within our organization or from entities with which HMS engages are encouraged to report such violations to their designated reporting channels or otherwise report such concerns directly to the Legal Department.

Confidentiality and Non-Retaliation

All reports of ethical concerns will be treated with the utmost confidentiality and will strictly be shared with parties on a ’need-to-know’ basis. HMS prohibits any retaliation against individuals who report ethical concerns in good faith.

Escalation

All cases of ethical concern must be escalated to HMS’ General Legal Department and where applicable, to the entire Executive Management who are charged with further investigation and resolution.

13. Review of this Code

This Code will be reviewed on an annual basis.

14. Approval of this Code

This Code has been approved by the Board of Directors of HMS.