Principle 1: Integrity. Phoebe will strive to ensure integrity in all activities conducted by or on behalf of the organization, and promote honesty in all levels of interaction within the organization.

Principle 2: Legal Compliance. Phoebe will strive to ensure all activity by or on behalf of the organization is in compliance with applicable laws.

Principle 3: Business Ethics. In furtherance of Phoebe's commitment to rigorous standards of business ethics and integrity, Trustees, Officers, and employees will strive to represent Phoebe accurately and honestly and will not engage in any activity or scheme intended to defraud anyone, including federal, state or local governments, of money, property or services.

Principle 4: Confidentiality. Phoebe employees shall strive to maintain the confidentiality of resident and other confidential information in accordance with applicable legal and ethical standards.

Principle 5: Conflict of Interest. It is the policy of Phoebe that all Trustees, Officers, employees and other representatives must avoid potential conflicts of interest. A potential conflict exists whenever a Trustee, Officer, employee or other representative has an outside interest, direct or indirect, which conflicts with the individual's duty to Phoebe or adversely affects the individual's judgment in the discharge of his or her responsibilities to Phoebe. The appearance of a conflict of interest may be just as damaging to Phoebe's reputation as a real conflict.

Principle 6: Business Relationships. Business transaction with ancillary providers, vendors, contractors and other third parties shall be transacted free from offers or solicitation of gifts and favors or other improper inducements in exchange for influence or assistance in a transaction.

Principle 7: Protection of Assets. All employees will strive to preserve and protect Phoebe's assets by making prudent and effective use of Phoebe resources and properly and accurately reporting its financial condition.

Principle 8: Reporting Suspected Misconduct. All Trustees, Officers, employees and agents are expected to report suspected violations of any statute, regulation, or guideline applicable to Federal health care programs or of Phoebe's own Policies and Procedures.

Principle 9: Compliance with Labor and Employment Laws. Phoebe will strive to maintain compliance with applicable labor and employment statutes, regulations and internal policies.