SPECIALTY1 PARTNERS ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG) OVERVIEW
Endo1 Partners Holdings, LLC dba Specialty1 Partners and its subsidiaries Endo1 Partners, LLC, OS1 Partners, LLC and Perio1 Partners, LLC (“Specialty1” or the “Company”) recognize the importance of being responsible environmental stewards, fostering a positive work environment, and conducting business ethically, transparently and with clear governance. The Company prioritizes management of environmental, social and governance (“ESG”) considerations throughout the business. Specialty1 and its doctor partner practices are committed to operating in a safe, respectable and sustainable manner. Specialty1 follows federal, state, and local regulations and requirements, and Specialty1 aims to minimize our environmental footprint. We work in close partnership with our doctor partner practices to operate without environmental incidents, and to promptly address and satisfactorily resolve any concerns.
Specialty1 was founded and is managed by endodontists. As such, Specialty1 is in a unique position to focus on the clinical needs and compliance matters in support of its doctor partner practices.
Specialty1 has also focused on creating a work environment that prioritizes ethical and responsible operations. To this end, Specialty1 prioritizes safe operations that are built on a culture of responsible operating procedures and reinforced by ongoing training.
Specialty1 is committed to sound governance and is led by an experienced leadership team which reports to a Board of Directors. Integral to Specialty1’s governance are the Company’s policies and procedures for Corporate Governance, Compliance, Cyber Security and Waste Disposal. Specialty1 has also adopted and implemented policies for Environmental Protection, Health and Safety, Diversity and Gifts and Entertainment best practices each of which are described below.
Please contact William Getschow, Specialty1’s General Counsel, at email@example.com and/or 713.392.4974 or Tony Manderschied, Specialty1’s Chief Compliance Officer, at firstname.lastname@example.org and/or 319.493.8951, with any questions concerning Specialty1’s approach to ESG compliance and/or the policies and procedures outlined below.
Specialty1 is led by an experienced leadership team committed to strong corporate governance practices. Specialty1’s management team reports to a Board of Directors and is accountable for sound management and risk management efforts. Specialty1’s management team is in regular communication with its Board of Directors which provides strategic oversight of the Company and its management team. Specialty1’s management and its Board of Directors are committed to the sustainability of Specialty1’s business model, which includes ESG performance and accountability. Critical business issues, including ESG issues such as safety, compliance, operations, and human resources, among others, are typically discussed with the Board on a quarterly basis or more frequently, as needed.
The Company has safeguards in place to prevent unapproved, unethical and unsafe practices including:
-Mechanism for reporting misconduct, any violation of law or policies or fraud through a dedicated email
address and/or phone number and a process for conducting confidential internal investigations, when
-Regular communications and training for employees, consultants and contractors concerning approved practices, activities and reporting of any perceived concerns.
-Management implemented control environment which establishes processes and procedures to prevent fraudulent or illegal activity.
The Company has established a Compliance Committee and separate Clinical Governance Committee of the Board. The Compliance Committee meets at least quarterly and is responsible for internal compliance controls, training and implementation of compliance policies and best practices. The Clinical Governance Committee meets monthly and is comprised of fourteen (14) doctors from the Company’s partner offices. The Clinical Governance Committee has oversight over clinical technology and practice innovations and credentialing review and compliance.
The Company utilizes the resources and practices of its partner offices to ensure the most state of the art practices and technologies are being utilized to ensure the safest and most advanced treatment of the patients by the Specialty1 doctor partner practices.
The partner doctor offices of the Company retain clinical autonomy from the Company but receive the support of the Company, including through the Compliance Committee and the Clinical Governance Committee.
Specialty1 offers the HealthFirst OnTraq waste management system for Amalgam, Lead, Medical Waste, Pharmaceutical and Sharps. The doctor partner practices of Specialty1 may utilize the HelathFirst OnTraq system or the practice’s own waste management system. Specialty1 and each of its partner doctor offices comply with all applicable laws, rules and regulations for waste management and disposal, including local and state health departments. Specialty1 recommends the use of amalgam separators and an amalgam recycling program to its doctor partner practices where they are not otherwise required. Specialty1 partner offices also comply with state specific hazardous waste and pharmaceutical waste disposal requirements. Specialty1 also recommends to its doctor partner practices the use of mail-back systems for transporting sharps.
GIFTS AND ENTERTAINMENT
Specialty1’s Gifts and Entertainment Policy establishes requirements for all Specialty1 officers and employees and any agents, consultants, business partners or other third parties engaged in operations on behalf of Specialty1.
Specialty1’s employees, agents and consultants are required to attend annual trainings on Anti-Bribery and Corruption and provide annual acknowledgement of Specialty1’s requirements as part of such training.
Specialty1 has established processes and procedures for reporting any perceived violations and Specialty1’s General Counsel, Chief People Officer and Chief Compliance Officer are dedicated to reviewing and investigating any reported violations. In addition, Specialty1 utilizes third party legal and advisory resources for assistance in investigations, as deemed necessary.
Specialty1 recognizes that cyber security is growing increasingly important and the Company has an established process to assess and address potential cyber risks and/or threats. Specialty1 has implemented what it believes to be a comprehensive information security and cyber-security program as well as an incident response plan. As part of this program, Specialty1 conducts regular employee training and has implemented data loss prevention systems.
Specialty1 has an Information Technology and Computer Use Policy which employees are required to acknowledge and agree to annually. In addition, Specialty1 conducts regular training on cyber security threats and has conducted internal campaigns for reviewing effectiveness of Specialty1’s policies and training.
Specialty1’s wire transfer and cash disbursements policy is further designed to prevent unauthorized and unapproved transfer of funds which are requested as the result of cyber security threats.
Specialty1 has undergone a third-party assessment of it’s cyber security measures and practices and continues to evolve the program based on changing risks and best practices.
Specialty1 is committed to responsible operations and complies with federal, state, and local regulations and actively manages its environmental footprint.
Specialty1 believes that environmental health is an important consideration for each of its doctor partner practices and as such we focus on waste reduction, including recycling and reducing the use of paper products. Specialty1 also utilizes natural lighting, occupancy sensors and LED bulbs whenever possible.
Specialty1 utilizes cutting edge technology to ensure that the policies and procedures which Specialty1 has instituted as a part of Specialty1’s environmental, social and governance focus are followed and maintained.
The Clinical Governance Board reviews and recommends the most state of the art technologies to the Specialty1 doctor partner practices. Specialty1 is in a unique position to be able to utilize the findings and experiences of doctor partner practices to recommend the same innovations to other practices which are supported by Specialty1.
COMPLIANCE AND AUDITS
As part of the due diligence process for every transaction undertaken by Specialty1, we engage third party consultants and advisors to audit the clinical practices of doctor partner practices. Specialty1 further performs routine chart reviews of doctor partner practices and such chart reviews are reviewed by the Compliance Committee of Specialty1.
The legal department of Specialty1 is involved in any audit reviews and supports the Compliance Committee through weekly meetings with the Compliance Manager.
Specialty1 supports its doctor partner practices by providing standard forms and policies for consent forms, reporting and compliance.
Health and Safety
Specialty1 is committed to managing our assets and operating in a manner that protects the health and safety of employees, contractors, communities, partners, and the environment. Specialty1 operates in compliance with all applicable health, safety, and environmental regulations and standards.
The employees of Specialty1 and the doctor partner practices of Specialty1 are regularly trained on the safe operating procedures. Specialty1 performs regular audits of the same and provides regular correspondence to the Specialty1 doctor partner practices on lessons learned.
Specialty1 is committed to diversity in the workplace and supports and values an environment of inclusion. Diversity in the workforce facilitates the introduction of new ideas and perspectives to help the Company operate responsibly and prosper.
Specialty1’s Integrity Guide was designed to support full compliance with applicable laws and practical ways we put our values to work every day, applying ethical principles to business decisions that deliver results the right and responsible way.
Specialty1 has policies and procedures in place to ensure compliance with applicable laws and has a compliance team to investigate any reports which can be made anonymously through dedicated telephone and electronic mail methods.
Specialty1 proactively engages in the communities where we operate, including local community groups and charitable groups. Specialty1 wants to be engaged in the communities where its doctor partner practices are located and provide supports to social organizations both in such communities and the communities of its corporate headquarters.
Specialty1 doctor partners and employees are encouraged to provide time and monetary support to charitable and social organizations and are given the time and tools to do so.
The Specialty1 management team embraces and promotes actions to operate responsibly and ethically. Specialty1 operates with a focus on protecting and working with the communities in which we work and live.
Specialty1’s employees, agents and consultants continuously strive to amend and modify Specialty1’s practices and procedures to enable Specialty1 to most effectively operate in harmony with the environment and take all available measures to ensure health, safety, diversity and security and appropriate governance for Specialty1’s operations.
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