Code of Ethics

1. COMPLIANCE WITH THE LAW

Travel Nurse Across America will comply fully with all relevant local and federal laws, guidelines and regulations, including those which are industry specific, governing our operations.

It is the responsibility of all employees to ensure, by taking legal or other expert advice where appropriate, that they are aware of all local and federal laws and regulations which may affect the part of the business in which they are engaged, including tax and exchange controls.

Even where the law does not apply, applicable standards of ethics and morality relate to our activities and require the same diligence and attention to good conduct and citizenship. Employees must avoid situations where appearance of impropriety exists, even though the circumstances might not otherwise specifically violate this code of conduct.

2. CONFIDENTIAL INFORMATION

Employees must not make use of confidential information obtained through their employment for personal gain, nor disclose such information to any third party during or after their employment. “Confidential information” is either information that has been specifically described as being confidential or is otherwise obviously confidential from the surrounding circumstances.

The term “confidential information” does not include information already in the public domain, information that was already known to the Recipient at the time of its disclosure, or information that is required by law to be disclosed.

3. CONFLICTS OF INTEREST

Sales of the company’s services and purchases of products and services from suppliers will be made solely on the basis of quality, performance, price and value, and never on the basis of giving or receiving inducements in the form of payments, gifts, entertainment or favors in any other form.

Every employee has a duty to avoid business, financial and other direct or indirect interests or relationships which conflict with the interests of Travel Nurse Across America, or which divides his or her loyalty to the company. Any activity which even appears to present such a conflict must be avoided or terminated unless, after disclosure to the appropriate level of management, it is determined that the activity is not unethical or improper, does not compromise integrity and is not detrimental to the reputation and standing of Travel Nurse Across America

4. SOLICITATION

Travel Nurse Across America's traveling professionals will not solicit full-time facility healthcare staff while on duty.

5. BUSINESS PRACTICE and ENTERTAINMENT

Travel Nurse Across America is resolutely opposed to bribery and corruption in any form. Gifts or entertainment may only be offered to a third party if they are consistent with customary business practices in the relevant territory, are modest in value, and cannot be interpreted as inducements to trade. Where there is doubt, guidance should be sought from the VP of HR. No financial or other inducements will be given to third party organizations or to individuals from such organizations in any circumstances.

Employees will not accept gifts, money or entertainment from third party organizations or individuals where such offerings might reasonably be considered likely to influence business transactions. Unsolicited gifts, other than trivial ones with a low value, should be returned. In a culture where such an action might cause offense, the gift will be declared to the company and, if practical, donated to an appropriate charity.

6. ACCOUNTING STANDARDS and RECORDS

All accounting documentation must factually identify the true nature of business transactions, assets and liabilities in conformity with generally accepted accounting principles. No record or entry must be false, distorted, incomplete or suppressed.

7. EXTERNAL REPORTING

Travel Nurse Across America may be required to make statements or provide reports to regulatory bodies, government agencies or other government departments. Care should be taken to ensure that such statements or reports are correct, timely and not misleading. Senior management must be made aware of any sensitive disclosure before it is made.

Care must also be taken when making statements to the media that information given is correct and not misleading. Inquiries from the media should be referred to Travel Nurse Across America's media relations experts and statements should only be made by designated spokespersons.

8. POLITICAL CONTRIBUTIONS

Travel Nurse Across America does not make contributions to political parties. There are no exceptions to this policy.

9. EMPLOYEES and HUMAN RIGHTS

Travel Nurse Across America supports the principles of Human Rights and is committed to upholding these principles in its policies, procedures and practices. Respect for human rights is, and will remain, integral to our operations. We respect freedom of association and the right to collective bargaining in accordance with local legislation and practice.

In dealing with our employees, we will act in compliance with all regulatory requirements and government guidelines. We will not discriminate on the basis of gender, color, ethnicity, culture, religion, sexual orientation or disability.

Employees will be paid and work hours at least as favorable as the terms established by agreements or industry standards.

We will take measures to ensure that the work of our employees does not compromise accepted human rights conventions, while recognizing and respecting the diversity in local cultures across the different communities in which we operate.

We will endeavor to ensure that we work with business partners who conduct their business in a way that is compatible with our policies of respect for human rights and ethical conduct. We will work with customers to ensure that contractual requirements do not infringe human rights.

We value all our employees for their contribution to our business. Their opportunities for advancement will be equal and not influenced by considerations other than their performance, ability and aptitude.

Employers' obligations to employees under labor or social security laws and regulations are respected. The business and employees will work towards creating permanent long-term relationships. To achieve a working environment in which team spirit and commitment to Travel Nurse Across America goals and values are maintained, the company will ensure that individual employees are treated fairly, with dignity and respect. Employees will also be provided with the opportunity to develop their potential and, if appropriate, to develop their careers further with the company.

Travel Nurse Across America places the highest priority on promoting the health and safety of employees while at work. In particular, it will constantly review the effectiveness of its methods of operation to best protect those who work in a high-risk environment.

In order to protect the interests of its customers and employees, and because of the nature of its business, Travel Nurse Across America will apply rigorous pre-employment screening and selection techniques.

10. INTERNAL SUPPLIERS

Any business transactions between Travel Nurse Across America and suppliers for the supply of goods or services should be based on normal 'arm's length' business principles. These principles should cover pricing and other contractual terms and must be as defensible as those to which independent parties might be expected to agree.

11. CLIENTS

Mutual trust and confidence between Travel Nurse Across America and its clients is vital. All employees should strive to consistently deliver excellent service and value by meeting the clients' expectations and by anticipating their changing requirements.

12. SUPPLIERS

All suppliers are entitled to fair treatment and all potential suppliers should have a reasonable opportunity to win Travel Nurse Across America's business. It is Travel Nurse Across America's policy to pay suppliers on time in accordance with agreed terms of trade. Travel Nurse Across America sets high standards for its suppliers in the context of its own ethical policy.

13. COMPETITORS

Travel Nurse Across America will always compete vigorously, but in a fair and ethical way. Competitive success is built on providing good value and excellent services. When in contact with competitors, employees will avoid discussing confidential information and no attempt will be made to improperly acquire competitors' trade secrets or any other confidential information. Employees must not discuss pricing strategies or undertake any arrangements which would conflict with the laws of the territory concerned.

14. COMMUNITY

Travel Nurse Across America will serve local communities by providing good employment opportunities and effective services in areas in which it operates. The company will also support and assist the voluntary work and charitable fundraising efforts of employees.

15. ENVIRONMENT

We will conduct our business with respect and consideration for the environment. We will take steps to minimize any disturbance to communities as a result of our operations. As a service organization, our environmental impact is small in relation to manufacturing industries. However, in each of our operations we will strive to minimize our impact on the environment through reduction of waste, vehicle emissions and energy consumption.

16. EMAILS and USE OF THE INTERNET

Employees are permitted to use e-mails and the Internet where appropriate for their job. Limited personal use is also permitted in an employee's own time e.g. during breaks, in accordance with local guidelines. Employees should exercise due care to ensure that Travel Nurse Across America is not committed to any inappropriate or unauthorized liability.

Employees will not use the e-mail or Internet in any way which would be in breach of copyright, contract or license agreements. Derogatory comments about any organization or individual will never be made. The viewing or distributing of pornographic, pedophilic, violent or other offensive data is expressly prohibited. Any personal views in e-mails must be clearly marked as such. Employees will exercise due care to ensure that viruses or other harmful software are not knowingly imported or spread.

17. HARASSMENT

Harassment can be defined as unwanted behavior which a person finds intimidating, upsetting, embarrassing, humiliating or offensive. Conduct involving the harassment (racial, sexual or other) of any employee is unacceptable. Should an employee believe that he or she has been harassed; the matter should be raised with the VP of HR who will arrange for it to be investigated without delay, impartially and confidentially.

18. GRIEVANCES

Staff can expect that Travel Nurse Across America will give due consideration to constructive suggestions and will provide a considered and objective review of genuine concerns and complaints. Such concerns include fraud, misrepresentation, theft, harassment, discrimination and non-compliance with regulations, legislation, policies and procedures.

Concerns will be investigated impartially and confidentially in order to protect the rights of the employee. Employees who have concerns about potential unethical behavior should advise the VP of HR in the first instance. Employees may do this anonymously if they wish. To ensure that confidentiality is maintained, employees should not discuss such concerns with colleagues or other third parties, unless specifically authorized or as a legal requirement.

If the employee is dissatisfied with the response to the concern raised, or if the concern relates to a matter of exceptional gravity or sensitivity, he can contact the CEO of Travel Nurse Across America in accordance with company policy.

Additionally, provided the company has been given the opportunity to address the issue, employees may report any and all ethical or clinical issues to proper authorities without the fear of retaliation by Travel Nurse Across America. Any issue that the employee feels is too sensitive to discuss with the VP of HR of Travel Nurse Across America may report as necessary, and without retaliation, to The Joint Commission or CMS. Phone numbers are located on The Joint Commission Web Site or call: 1-800-944-6610.

19. POLICIES and PROCEDURES

Travel Nurse Across America has developed a set of policies and procedures to ensure that business is conducted appropriately and with minimal risks. Employees are accountable for their compliance with such policies and procedures, and shall make every effort to be aware of, and conform to, such standards.

20. IMPLEMENTATION

This Business Ethics Policy will be issued to and adopted by all employees of Travel Nurse Across America a minimum standard. Published on the intranet and incorporated into future employment contracts as applicable, it will be monitored as part of Travel Nurse Across America's compliance processes. The policy will be reviewed annually or as otherwise necessary.