Code of conduct

A message from our CEO

1.Introduction

1.1 Vision

Digital care and connectivity for every patient.

1.2 Mission

Our mission is to help healthcare providers expand their care services beyond brick-and-mortar, enabling hospitals and physician groups to remotely engage any patient. Our remote patient monitoring for post-episodic to chronic condition care can help patients live better, healthier and autonomous lives from the comfort and privacy of their homes.

1.3 Values

We first value respect, integrity and honesty in everything we do, at work and in life in general. We value the human spirit, intelligence and creativity, regardless of its ethnicity, gender identity, or religious beliefs. With these values deeply rooted, we act as collaborative partners with our customers, cohorts and suppliers. We seek open, candid, direct relationships where listening to others is as important as expressing ourselves. We strongly believe in fair agreements where all parties gain from the collaboration and the resulting value is greater than the sum of the parts. We thrive to be responsible and accountable, earning our customers' trust one week, one month and one year at a time. We trust and assume goodness in intentions. We are continuous learners, always aiming to better understand in order to better help, support and service.

2.The road to integrity

The Code of Conduct (the "Code") is approved by the Board of Directors of CareSimple ("CareSimple" or the "Group"). The Code applies to CareSimple and its subsidiaries and to all members of CareSimple worldwide. Without guiding principles, it is not easy to always know how to identify the right path to take, or, when it is identified, to follow it. Our Code establishes the foundations of the Group's corporate governance and includes a critical framework of principles, practices and procedures.

Who is governed. The Code applies to all board members and officers of CareSimple, as well as to full-time and part-time employees, and to all temporary, contractual and other individuals and companies that act on behalf of CareSimple, wherever they are located — collectively, our "workforce." We expect all third parties with whom we do business to comply with the Code, and applicable provisions are included in third-party contracts.

Your responsibilities. Whenever and wherever you work on behalf of CareSimple, you must abide by the Code. You are expected not only to know and follow it, but also to uphold it by promptly reporting activities that are not in accordance with its letter or spirit. All members are expected to treat others as they expect to be treated, including customers and other external parties.

The elements. CareSimple's integrity system includes three principal elements — Principles (overarching statements of our commitment to important values), Practices (the specific conduct required of all of us), and Procedures (more detailed operational approaches to achieving compliance).

Effective date. This CareSimple Code of Conduct is effective as of January 1, 2021, and is reviewed and approved by the Board of Directors on an annual basis.

3.The guiding principles of the Code

These eight principles describe what we stand for. Each is supported by examples of expected and prohibited behaviors that guide our daily conduct.

3.1 Respect for the person

CareSimple is committed to the principle of employment equity and believes that every person is entitled to fair treatment, courtesy and respect. Building relationships based on trust and mutual respect is essential to the development of the Group and its culture.

We respect the individual regardless of origin, physical characteristics, sexual orientation, beliefs, opinions or social condition, and do not tolerate any form of discrimination, violence, harassment or intimidation. We embrace diversity, actively promote inclusion, protect the health and safety of individuals, and safeguard personal information strictly in accordance with applicable laws.

We do not propagate defamatory statements; possess illegal drugs, weapons or prohibited materials in the workplace; recruit or dismiss on discriminatory criteria; or disclose personal information without right. CareSimple applies a "zero tolerance" approach to harassment in all its forms.

3.2 Respect for our clients and customers

Our clients are at the center of our daily activities and we are committed to providing them with exceptional service. We want relationships based on clarity, honesty, integrity, attentiveness, quality of execution, efficiency and courtesy, and we are firmly committed to ethical sales practices.

We do not use deceptive or aggressive sales practices; insult, harass or disparage a customer; obtain, disclose or retain personal information without right; treat clients on discriminatory criteria; or discuss, offer or accept bribes from customers in any form.

3.3 Respect for the community

As we strive to outperform our competition, we do so honestly, openly, fairly and with integrity. We operate with "zero tolerance" for bribery and corruption and do not allow third parties representing us to engage in such conduct. We support the economic, social and cultural development of the communities where the Group operates.

We do not mislead or obstruct any institution or regulatory body; accept, authorize, pay or conceal bribes or improper benefits; solicit personal benefit in connection with our job duties; or falsely claim that CareSimple supports an activity of a personal nature.

3.4 Respect for the environment

In all its activities, CareSimple is concerned for the environment and is firmly committed to progressively reducing its environmental footprint. We comply with all applicable environmental laws, promote responsible purchasing, reduce and properly recover waste including electronic waste, and use resources and energy economically and efficiently.

3.5 Respect for the Group and its interests

The continued success of CareSimple depends on honest, transparent, loyal and effective relationships. We act with honesty, loyalty and transparency; avoid actions that could adversely affect the Group's competitive position; avoid conflicts of interest (real or perceived) and report them immediately; protect confidential information; and do not engage in insider trading.

Receiving and giving gifts and entertainment

• The total value of any gifts or entertainment provided or received, including meals and tangible gifts, should not exceed $100 per person each year. This limit applies to both giving and receiving.
• Only corporate-branded items (such as CareSimple t-shirts or similar merchandise) are acceptable as gifts, and their value must remain under the monetary limit. Unbranded gifts, regardless of value, are not permissible.
• Paying for or accepting meals as part of business interactions is allowed, provided the cost does not exceed the monetary limit per person.
• If a gift exceeding the set limit is received, it should be politely declined; if declining is not feasible, it should be reported to management for appropriate handling.
• Soliciting gifts, hospitality, or entertainment for personal benefit is strictly prohibited at all times.

3.6 Respect for the law and applicable rules

It is the policy of CareSimple to comply in all material respects with the laws and regulations that apply to its operations. It is never acceptable to violate laws and regulations, even if we believe we are acting for the good of the Group. We ensure compliance with all applicable securities laws, accounting standards and controls, and anti-bribery laws in the countries where we operate.

3.7 Respect for commercial norms and trade standards

While profits are undeniably important, they are not everything — how we generate them is also important. We achieve success by demonstrating excellence, not by disparaging our competitors; we collect competitive information ethically and legitimately; and we ensure all activities, transactions and cash payments are clearly documented and properly recorded.

3.8 Respect for the Group policies and procedures

We want to do business the right way, in a consistent, disciplined and rigorous manner. We ensure we are aware of the policies and procedures that apply to our functions; we ensure any deviation is fully and honestly justified, reported, and approved by the appropriate authority; and we comply with both the letter and the spirit of those policies.

4.Closing thoughts

Thank you for taking the time to read the CareSimple Code of Conduct. You represent CareSimple, and the communities with which we do business are all affected by our actions and benefit when we do the right thing. We count on you to uphold our commitment to excellence and integrity by always respecting the spirit of the Code. Remember that we're a team and that there are many resources available to help you.

Elliot Francoeur, CHRP
Director of Human Resources

5.Appendices — resources & support

Learning how to make your voice heard is one of the key elements in building CareSimple's culture of trust. If you observe or become aware of conduct that is not consistent with the spirit of the Code, take ownership of the situation and take action. Reports or inquiries can be conducted anonymously, and retaliation against anyone who raises an issue in good faith will not be tolerated.

For questions involving	Resource
Any violation of the Code of Conduct, company policies and applicable laws and regulations. All disclosures of conflicts of interest. Concerns regarding accounting, internal accounting controls or auditing matters (confidentially or anonymously).	E-mail: ethics@caresimple.com Mailing address: Human Resources (ETHICS), 3801 PGA Blvd, Suite 600, Palm Beach Gardens, FL 33410, United States
Requests by external organizations to participate in a survey	Manager and Human Resources or Compliance Departments
Requests for input from external parties (media, investors, etc.)	Communications and Marketing or Investor Relations Department
Security issues	Manager and Human Resources or Security Department