As part of our corporate mission, GCX Healthcare Solutions (“GCX”) is committed to the highest standards of ethical business conduct. This GCX Code of Business Conduct & Ethics (the “Code”), summarizes GCX’s compliance and ethical policies for all employees. For the purposes of this Code, all GCX Board Members, Company Officers, independent contractors, and employees are considered “Employees”. The Code is intended to define GCX’s expectations for how Employees should conduct day-to-day business, help drive decision-making, and create a culture of compliance. GCX expects all Employees to read and become familiar with the policies and expectations described within this Code.