Integrity: A Fundamental Value

Quest’s vision is to empower better health through diagnostic insights. Our ability to achieve that vision is dependent on one of our key values, integrity. We strive to operate ethically, honestly, and responsibly, in accordance with our Code of Ethics.

Our commitment to ethical business conduct

We are committed to adhering to all applicable laws and regulations in our work as a healthcare leader. We have a clear strategy to maintain a culture of compliance and integrity at Quest that engages all our employees and emphasizes the importance of ethical behavior through our policies, training, assessments, and reporting practices.

Policies

Quest’s Code of Ethics is critical to our success, empowering us with the roadmap we need to earn and maintain the trust of our patients, customers, shareholders, and colleagues. Our Code is not merely a set of rules—it defines our approach to making good decisions no matter what our role is and creates a shared sense of pride among all of us.

Our Code and compliance policies apply to all employees, subsidiaries, vendors, contractors, suppliers, interns, business partners, and representatives who work on our behalf. We expect the best from ourselves and one another, including a commitment to Quest’s core values of leadership, integrity, quality, innovation, collaboration, and accountability.

We expect one another to ask questions and take action if something isn’t right. Employees who have concerns are encouraged to share them with their manager; a representative from our Human Resources, Compliance, or Legal departments; or confidentially or anonymously through our hotline or online inquiry form.

Training

We look to our managers and supervisors to always promote our Code and model the right behaviors. This includes creating an open-door environment, making it clear that any form of retaliation is unacceptable when an employee raises concerns, ensuring employees are properly trained, and being fully present to offer guidance and support. All full-time, part-time, and contract employees are required to complete training upon hire as well as on an ongoing, annual basis. The training topics include compliance, fraud, and abuse; privacy; corruption; bribery; and our Code of Ethics. Select employees are also trained on compliance with the Foreign Corrupt Protection Act (FCPA). Our compliance training program is reviewed as part of our internal audit process, with select segments overseen by our Legal department.

Risk assessment

The best way to assess compliance risks—and the capacity to effectively address those risks—is to do so consistently and continuously throughout the year. We expect all employees to identify any compliance issues within their areas of responsibility.

The company engages in an annual risk assessment specific to compliance, assessing and categorizing compliance risks regarding severity and the level of mitigation required. The Compliance Risk Assessment is conducted at the direction of counsel and is an element of the enterprise risk management (ERM) program.

Reporting process

We routinely communicate with employees on how to confidentially report a violation of the Code and take all reports of violations extremely seriously. Reports are investigated by the Compliance, Human Resources, and/or Legal departments, as appropriate. If the investigation reveals a violation of a compliance policy, the Compliance department oversees any necessary corrective action including discipline up to and including termination. The corrective action taken is dictated by the type of issue involved, based on the circumstances and facts gathered during the investigative process, and consistent with written disciplinary guidelines. Our Senior Vice President of Compliance provides oversight on the program and reports directly to our CEO.

Our commitment to human rights

We are committed to protecting human rights across our operations, including our supply chain. We’re proud to share our human rights policy, and we believe that protecting and supporting human rights is our fundamental responsibility as an employer. We comply with all applicable employment and human rights laws and regulations where we have operations to ensure alignment with our values.

• We provide fair and equitable wages, benefits, and other conditions of employment in accordance with local laws and regulations.
• We do not allow child labor in our operations.
• We do not use or engage in any form of coerced, indentured, or prison labor.
• We provide a safe and healthy work setting, including PPE and the tools to work safely.
• We promote a workplace that is free of discrimination and harassment and prohibit threats or abuse.
• We embrace diversity in the workforce and supplier base, create an environment that promotes diverse opinions and equal opportunity, and operate in a way that treats all people with respect and dignity.

Enterprise risk management begins with awareness

We maintain an enterprise risk management (ERM) program overseen by our Board of Directors and driven by our C-suite executives that is designed to promote risk awareness throughout the company’s key business, operations, and support functions.

Our program, which is integrated with the company’s governance, performance management, and internal control frameworks, entails a formal continuous process that identifies, assesses, mitigates, and manages the risks from both internal and external conditions that could significantly impact the company and influence its business strategy and performance.

The program is based on the most recent framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) and focuses on operational, financial, legal, compliance, and strategic risk.

As part of the program, together with our Board of Directors, we routinely assess our enterprise-level risks, emerging risk factors, overall company-level risk tolerance, and the effectiveness of our risk management, as well as monitor the progress of and resources applied to risk mitigation. In addition, we continue to strengthen the alignment of our ERM program with our key environmental, social, and governance (ESG) areas of focus.

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