I. PURPOSE

The purpose of this policy is to provide an overview of Nearshore,  compliance program’s policies and procedures (the “Compliance Policies”). Nearshore recognizes the importance of conducting business in an ethical, lawful, and socially responsible manner and strives to maintain the highest legal and ethical standards in conducting its business. In developing, implementing, and applying its Compliance Policies, Nearshore is guided by applicable federal and state law, including the U.S. Department of Health and Human Services Office of Inspector General’s seven fundamental elements of an effective compliance program. Compliance Policies empower the Company to foster a culture of compliance while identifying fraud and abuse risk areas. The Company is dedicated to implementing polices through training and education, auditing and monitoring, anonymous reporting, investigations, corrective action and discipline when necessary.

Nearshore expects all Company employees, directors, management, and individuals contracted by the Company to provide staffing support or related services directly to Nearshore customers (collectively, “Personnel”) to comply with all Nearshore Compliance Policies. The Compliance Policies is made available to all Personnel and an effective line of communication is continuously established and refined for all Personnel. The Company’s Non-Retaliation and Non-Retribution Policy and Compliance Hotline Policy establishes protections for, and extensive lines of communications permitting, anonymous reporting of noncompliance with these Compliance Policies and applicable laws in order to support an effective compliance program.

Nearshore is currently operationalizing a corporate affiliate dedicated exclusively to healthcare related staffing services. While independent policies and procedures governing its operations remain under development, those policies and procedures listed herein and expressly referencing this Wrapper Policy shall exclusively govern operations related to Company Personnel involved in healthcare services, providing services in any healthcare setting, or on behalf of, or for the clinical benefit of, healthcare providers or their designees.

II. COMPLIANCE POLICIES OVERVIEW

The Company’s Compliance Policies supplement and conform to its Code of Business Conduct and Ethics. The Compliance Officer (“CO”) and Compliance Committee (“CC”) are tasked with enforcing these policies where applicable, as well as updating them as necessary. Policies generally fall into three categories: (i) Program Structure and Operations; (ii) Employee/Personnel Conduct; and (iii) Data Privacy and Security. These categories of Compliance Policies are designed to overlap and compliment one another in order to establish a robust set of expectations and practices for all Personnel.

PROGRAM STRUCTURE AND OPERATIONS

EMPLOYEE / PERSONNEL CONDUCT

DATA PRIVACY AND SECURITY

III. CONFLICTS OF AUTHORITIES

Nearshore’s Compliance Policies supplement (and do not replace) laws, regulations and government rules. As a general matter, laws, regulations, and other government rules control over the standards set forth in the Compliance Policies unless the Compliance Policies impose stricter requirements than these authorities. Questions regarding the application of any laws, regulations, or government rules may be directed to Nearshore’s Compliance and Legal Department as appropriate. Compliances Policies are reviewed at minimum annually to accommodate for updates to federal and state laws.

IV. QUESTIONS RELATING TO INSIGHT GLOBAL’S COMPLIANCE POLICIES

The Compliance Policies do not address every situation that may arise. The absence of a specific guideline, however, does not relieve Nearshore’s Personnel of the responsibility for operating with the highest ethical standards of business conduct. Any questions concerning the Compliance Policies or any other legal or business ethics matter not specifically addressed in the Compliance Policies should be directed to the Compliance and Legal Department.

For more information, go to our Corporate Ethics Hotline.

V. APPROVAL/MAINTENANCE

This policy is approved by the Compliance Officer and/or the Compliance Committee. Maintenance of this policy will be the responsibility of the Compliance Committee in coordination with the Compliance Officer. The chart above is updated regularly to account for any recent changes or updates to Nearshore Compliance Policies.