1. Compliance With Laws

1.1 Phox’s Couriers shall comply

with all applicable laws and

regulations, including but not

limited to laws and regulations

relating to customs, labor,

mandatory insurance, social

payments, provident fund

contributions, corporate taxes,

the supply of goods and/or

services, patient privacy and

health and safety.

2. No Child Or Forced Labor

2.1 Phox is against slavery,

including all forms of modern

slavery such as forced labor,

bonded labor, serfdom,

trafficking in persons, and the

exploitation of children for labor.

All work must be performed on a

voluntary basis, and employees

must be free to leave their jobs.

Overtime work must be

voluntary and subject to

reasonable and legally compliant

compensation.

2.2 Phox’s Couriers shall comply

with all applicable laws and

regulations at all times when

employing young workers and

shall ensure that all young

workers are adequately

protected.

2.3 Phox’s Couriers are also

expected to prohibit all forms of

slavery, as defined above, in

their operations.

3. FAIR WORKING CONDITIONS

3.3 Phox is against all forms of

discrimination, differential

treatment, harassment, and

inappropriate or unreasonable

interference with work

performance, whether this

behavior is based on race or

ethnicity, gender (including

gender identity or expression),

nationality, disability,

background, religious, political,

or sexual orientation.

3.2 Phox’s Couriers shall support

the standards and rights stated

in this section and provide a

workplace without disrespect,

harassment, abuse, unlawful

practices or discrimination.

3.3 Phox’s Couriers shall comply

with the applicable local labor

laws relating to minimum wage,

fair working hours, the freedom

of association, and right to

collective bargaining.

4. FAIR WORKING CONDITIONS

When Phox’s Couriers engage in negotiations or business dealings with Phox, they confirm that they and their employees have not and will not violate any principles of good governance required by this section, and will ensure that their relevant subcontractors observe the same standards and principles in this Code of Conduct.

Anti-Bribery and Corruption.

4.1 Phox has zero tolerance towards

any corruption or bribery by its

employees, agents, contractors,

Couriers or their subcontractors.

4.2 Phox’s Couriers shall conduct

business in an ethical and lawful

manner that complies with all

laws and regulations concerning

anti-bribery and corruption.

Couriers shall prohibit their

employees, agents, contractors,

and couriers from engaging in

corrupt behavior. Corrupt

behavior includes:

(a) Directly or indirectly offering

any incentives, privileges,

benefits, or other advantages

such as cash, compensation,

or gifts (“Advantages”) to our

other Couriers, government

officials, Phox clients,

patients, or Phox employees

(including but not limited to

their relatives);

(b) Seeking any Advantages

from our other Couriers,

government officials, Phox

clients, patients or Phox

employees (including but not

limited to their relatives); and

(c) Accepting any Advantages

from other Couriers,

government officials, Phox

clients, patients, or Phox

employees (including but not

limited to their relatives).

4.3 Couriers shall immediately notify

Phox if any of its employees

request or accept, directly or

indirectly, any monetary gift or

benefit, or products.

Competition

4.5 Phox observes at all times the

principles of fair competition

and abides by the applicable

competition laws of the states in

which we operate. As a general

rule, such laws forbid

agreements or actions that

could limit or distort

competition or trade. Phox’s

Couriers shall abide strictly by all

applicable competition laws and

refrain from behaving in a way

that would appear to be or

would be considered anti-

competitive conduct (such as

rigging prices and sharing

information about prices with

their competitors).

Money Laundering, Financing Terrorism, and Other Criminal Activities.

4.6 Phox has zero tolerance towards

any criminal acts by its

employees, agents, contractors,

and/or its Couriers and their

subcontractors in the course of

doing business.

4.7 Phox’s Couriers must not

engage in money laundering or

any activity that facilitates

money laundering, funding of

terrorism, or other criminal

activities. Couriers shall

maintain financial records and

reports according to the

applicable laws and regulations.

Trade Regulations, Sanctions, and Debarment.

4.8 Phox complies with all applicable

export and import control,

sanctions, and customs laws and

regulations.

4.9 Phox’s Couriers shall comply

strictly with such laws and

regulations, and shall ensure

that their directors, officers,

employees, beneficial owner(s),

agents, contractors, and

partners are not listed on any

applicable sanctions and/or

debarment lists. Courier shall

immediately notify Phox with full

information if any of its

directors, officers, employees,

beneficial owner(s), agents,

contractors, and partners is

listed on any applicable

sanctions or debarment lists.

4.10 If Phox requires information

and documents from its

Couriers for any screening or

due diligence in relation to

trade regulations, sanctions, or

debarment, Couriers shall

cooperate and promptly

provide the same.

Conflicts of Interest.

4.11 A conflict of interest is any

direct or indirect relationship,

activity, involvement,

engagement, or obligation that

may affect the objectivity or

independence that is required

when carrying out duties or

responsibilities.

4.12 Phox’s Couriers shall

immediately declare any

relationships and actual or

potential conflicts of interest

that they or their directors,

officers, employees, or

stakeholders  may have

with Phox or its employees.

These include relationships

such as relations by blood or

marriage, investors, business

partners, or competitors. The

requirements in this section

are supplemented by Phox’s

Courier Operating Agreement

as amended by Phox from time

to time.

5. CONFIDENTIALITY, INFORMATION SECURITY, AND DATA PROTECTION

5.1 Phox takes confidentiality,

information security, and

personal data protection very

seriously. We strive to adhere to

all applicable data protection

laws, information security

industry standards, and

confidentiality obligations.

5.2 Phox expects its Couriers to

commit to doing the same.

Couriers shall comply with all

applicable requirements when

collecting, recording, hosting,

processing, transmitting, using,

or deleting personal data.

Couriers should also take

sufficient measures to ensure

the confidentiality and security

of information shared with and

processed by them.

Additionally, Couriers shall

comply with all contractual

requirements on confidentiality,

information security, and data

protection, and shall sign a

Business Associate Agreement

when requested by Phox.

5.3 Couriers shall ensure that their

directors, officers, employees,

stakeholders, agents,

subcontractors, couriers, and

partners comply with standards

at least as strict as those

mentioned here.

5.4 If the Courier or their

subcontractors performing

services for Phox violate any

protected health information or

personal data regulations or

experience any incident relating

to information security (such as

data leaks, ransomware attacks,

or other instances of breach of

confidentiality), the Courier

shall be responsible to

immediately notify Phox.

6. HEALTH AND SAFETY

6.1 Phox aims to uphold and

maintain high health and safety

standards. We require our

employees to comply strictly

with all of our on-site safety

rules and regulations, as well as

the applicable health and safety

best practices. We expect our

Couriers to observe the same

standards when supplying any

goods or services to Phox

clients and when conducting

their daily business operations.

6.2 Courier personnel who fail to

comply with Phox’s safety rules

and regulations may be

replaced immediately if

requested by Phox.

6.3 Phox’s Couriers shall take all

necessary steps to ensure that

their employees and others

involved in their operations can

work safely. Couriers shall have,

or work towards having, an

effective health and safety

management system through

which they are able to:

(a) Identify and control health and

safety risks;

(b) Reduce the risk of accidents;

(c) Comply with relevant laws and

regulations;

(d) Ensure necessary emergency

preparedness and prevention

measures are in place; and

(e) Improve overall workplace

safety and health performance.

6.4 Our Couriers are expected to

actively improve and strengthen

their respective safety culture

and safety and health

performance. This includes

providing the relevant safety

and health training and

equipment for their employees.

7. COMPLIANCE WITH THE COURIER CODE OF CONDUCT

7.1 Phox reserves the right to verify

whether its Couriers have

complied with the requirements

of this Code of Conduct at any

time, for example, through

Courier questionnaires,

declarations, or audits by either

Phox or a third party. Courier

shall comply with Phox’s

request to provide the relevant

information or for an audit. If

Phox requests for an audit,

Courier shall cooperate in all\

audits, including but not limited

to facilitating Phox’s and its

third-party auditors’ access to

Courier’s personnel,

documentation and

subcontractors relevant to the

audit. Phox’s Couriers shall

strive for continuous

improvement by setting

measurable targets on

progress.

7.2 Any breach of the obligations in

this Code of Conduct by Phox’s

Couriers, their directors,

officers, employees,

stakeholders, or their

subcontractors must be

reported to Phox immediately.

If the breach is curable, a

corrective action plan must be

presented to and approved by

Phox. Without prejudice to any

legal or contractual remedies

that Phox may be entitled to,

any incurable breach or failure

to satisfactorily cure a breach

may result in Phox terminating

the commercial relationship at

its discretion.

7.3 Nothing in this Code shall

modify or replace any additional

reporting obligations imposed on

Courier by Phox in our Courier

Operating Agreement, Business

Associate Agreement, or other

agreement imposing reporting

obligations.

8. HOW TO CONTACT PHOX

8.1 Couriers should contact Phox at

support@phoxhealth.com or

(844) 688-7469 if:

(a) there are any violations of this

Code of Conduct;

(b) any requirement to notify Phox

under this Code of Conduct is

applicable; or

(c) there are any queries on the

application or interpretation of

the requirements under this

Code of Conduct.

8.2 If there are violations or queries

relating to health, safety and/or

patient privacy, Couriers should

immediately within twenty-four

(24) hours contact Phox at

support@phoxhealth.com or

(844) 688-7469.