3.1 Commitment to the Code

Arrow Pharmacy Inc strives to conduct business in a fair and ethical manner, as well as abide by all Federal, State and local regulations as outlined in our Code of Conduct, Business Ethics and Conflict of Interest Policy found in Appendix A. We require all affected individuals including but not limited to employees to honor the same commitments and abide by the same standards listed in the Code of Conduct, Business Ethics and Conflict of Interest Policy. All affected individuals including but not limited to employees are required to read, agree to and abide by this Code of Conduct, Business Ethics and Conflict of Interest Policy.

Procedures for implementing and enforcing our Code of Conduct, Business Ethics and Conflict of Interest Policy:

The Code of Conduct, Business Ethics and Conflict of Interest Policy describes our commitment to do what is right. Any violations of the Code of Conduct, Business Ethics and Conflict of Interest Policy are subject to discipline as outlined in the Code and will be dealt with swiftly. listed below are Arrow Pharmacy Inc's procedures to police and steadfastly follow our Code:

1. Every affected individual including but not limited to employee will be supplied a copy of the Arrow Pharmacy Inc Code of Conduct, Business Ethics and Conflict of Interest Policy found in their Employee Compliance Training Handbook at the time of hire (first 30 days} and then no less than annually or whenever changes are made.
2. We provide a copy of our Code of Conduct, Business Ethics and Conflict of Interest Policy to any of our Vendors, Contractors, Third-Party Payers or other Business Associates and encourage them to enforce a code of conduct that reflects similar business and ethical standards for their organizations.
3. The Compliance Officer, Bhavin Antala, with the owner or any other agent designated by the owner, will review the Code of Conduct, Business Ethics and Conflict of Interest Policy on an annual basis to identify changes or updates needed to accurately reflect the business and ethical standards of Arrow Pharmacy Inc. All changes to the Code of Conduct will be approved by management.
4. All affected individuals including but not limited to employees agree to conduct business and act in a manner that reflects our high standards of Conduct at all times. All affected individuals including but not limited to employees, at the time of hire (first 30 days} and then no less often than annually or whenever changes are made, will sign an Employee Statement attached to the Code to acknowledge and attest that they received, read, understand and agree to abide by the Code of Conduct, Business Ethics and Conflict of Interest Policy.
5. Any violation of this Policy will result in disciplinary actions as outlined in the Code of Conduct, Business Ethics and Conflict of Interest Policy; up to and including termination of employment.

3.2 Conflicts of Interest

A "conflict of interest" arises when a personal, social, financial or political activity has the potential of interfering with an employee's loyalty and objectivity to their job and our pharmacy. Actual conflicts must be avoided; additionally, even the appearance of a conflict of interest can be harmful and should also be avoided. Described below are common ways that conflicts of interest can arise:

3.2.1 Employment & Affiliations Conflicts

Outside Employment and Affiliations: A position performing services (either paid or unpaid) for a person or entity that is a competitor, customer, business partner, Third-Party Payer, Medicare Part Dor MA sponsor, supplier or wholesaler of goods or services to our pharmacy; raises an actual or possible conflict of interest. This includes positions serving as a director or consultant.

Some arrangements of this kind are always impermissible - for example, if an affected individual, including but not limited to employee, receives additional payments for services which our pharmacy has already been paid. Another example would be the formation of financially motivated alliances with the intent to steer patients to or from one health care provider or resource. All affected individuals including but not limited to employees cannot make unauthorized disclosures of protected personal health information for personal gain. Yet another example that could be impermissible would be accepting incentives from manufacturers to dispense more expensive drugs to patients when lower cost alternatives are available. Employees are instructed to report any outside employment or affiliations to the Compliance Officer.

• Jobs and Affiliations of Close Relatives: The work activities of close relatives can create conflicts of interest as well. If an affected individual's, including but not limited to employee's, "close relative" works or performs services for any competitor, customer, business partner, Third-Party Payer, Medicare Part Dor MA sponsor, supplier or wholesaler; the affected individuals including but not limited to employee must promptly notify the Compliance Officer
• Boards of Directors: All affected individuals including but not limited to employees asked to serve on the board of directors of another organization may raise a conflict of interest. Serving on the board of directors of a community, charitable or nonprofit organization is usually okay and typically would not present a conflict of interest. All affected individuals including but not limited to employee involvement on other boards must be disclosed to the Compliance Officer, Bhavin Antala, before accepting a position as a board member.

3.2.2 Receiving Gifts and Entertainment-Conflicts

What are gifts and entertainment? Anything of value, including, but not limited to: discounts, loans, cash, favorable terms on any product or service, services, prizes, transportation, use of another's vehicle or vacation facilities, stocks or other securities, participation in stock offerings, home improvements, tickets, travel expenses (except those travel expenses incurred during trips made for the pharmacy) and gift certificates.

We believe it is a conflict of interest for all affected individuals including but not limited to employees to accept or to offer business gifts or entertainment of any significance to patients, Medicare Part D and MA plan sponsors, suppliers, wholesalers, manufacturers and other health care professionals. All affected individuals including but not limited to employees are required to follow our guidelines in regard to gift giving or accepting.

Gifts and entertainment offered to all affected individuals including but not limited to employees and their close relatives fall into three categories:

1. Usually okay.

This category includes promotional items of nominal value, such as pens, calendars, coffee mugs or cookies, which are given to customers in general. All affected individuals including but not limited to employees do not need to obtain review or approval before accepting "Usually Okay" Gifts.

2. Always wrong.

Some types of gifts and entertainment are never permissible.

All affected individuals including but not limited to employees may never:

• Accept any gift or entertainment that would be illegal or result in any violation of law.
• Accept any gift of cash or cash equivalent (such as loans, stock, stock options).
• Accept or request anything as a "quid pro quo" - in other words, as part of an agreement to do anything such as a business favor in return for the gift or entertainment.
• Participate in any activity that they know would cause the person giving the gift or entertainment to violate his or her own employer's standards.

3. Requires approval.

Gifts, gift certificates and entertainment that do not fit into the first two categories may or may not be acceptable.

Examples in this category include:

• Gifts, gift certificates and entertainment from a single source with an annual fair market value that is more than $100.

Before offering or accepting these kinds of gifts or entertainment, all affected individuals including but not limited to employees need to get approval from the Compliance Officer.

Any supplies, equipment, rebates, or other inducements received in conjunction with purchases made by our pharmacy which are promotional or inducements to purchase, shall become the property of the pharmacy and placed in service or awarded through direction from Management.

Procedures for Disclosing Potential Conflicts of Interest:

The policy of Arrow Pharmacy Inc requires all affected individuals including but not limited to employees to disclose any activity that has a potential of being construed as a Conflict of Interest. The following procedures ensure compliance with this policy:

1. All affected individuals including but not limited to employees must sign an Employee Statement regarding the Code of Conduct, Business Ethics and Conflict of Interest Policy that certifies their receipt, understanding, acceptance and includes the disclosure of any potential Conflict of Interest. This will occur at the time of hire (first 30 days) and then no less than annually thereafter.
2. If an affected individual, including but not limited to an employee, is unsure if an anticipated action presents a "conflict of interest" the Compliance Officer must be contacted for approval prior to - rather than engaging in the action without obtaining clearance and hoping for forgiveness after the fact.
3. Once disclosed, the Compliance Officer and Management must make objective decisions regarding a potential Conflict of Interest and take necessary action informing the involved affected individual including but not limited to an employee in a timely fashion.