Courier Code of Conduct

Effective: January 19, 2023

Phox Health, Inc. (“Phox” or “we” or “us”) is one of the leading healthcare technology companies dedicated exclusively to prescription delivery in the United States. We are committed to conducting our business affairs in a socially responsible and ethical manner consistent with our mission to support our hospital and pharmacy clients and their patients. We expect our Couriers to support us in this. Therefore, we have adopted the following courier Code of Conduct to ensure that goods and services provided to our clients are provided in a manner consistent with these principles.

This Courier Code of Conduct is a statement of Phox’s expectations and requirements with respect to Phox’s couriers and business partners (collectively, “Couriers”), as well as their employees and subcontractors who are performing services for Phox on behalf of these Couriers. This Code, along with our Courier Operating Agreement and Business Associate Agreement provide guidance for socially responsible, legally compliant business practices and describe Phox’s expectations for Courier policies and actions regarding labor standards, human rights, ethics, health and safety, patient privacy, and confidentiality.

This Code of Conduct may be supplemented or amended by us from time to time. Any interpretation of or determination required under this Code shall be resolved and reasonably decided by Phox and is binding on our Couriers. If our Couriers engage third parties (for example, subcontractors) when providing services to Phox, they shall ensure that such third parties also observe the principles and standards in this Code of Conduct.

1. Compliance With Laws


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


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.


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.


Phox’s Couriers are also expected to prohibit all forms of slavery, as defined above, in their operations.



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.


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.


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.


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.


Phox has zero tolerance towards any corruption or bribery by its employees, agents, contractors, Couriers or their subcontractors.


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:


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);


Seeking any Advantages from our other Couriers, government officials, Phox clients, patients or Phox employees (including but not limited to their relatives); and


Accepting any Advantages from other Couriers, government officials, Phox clients, patients, or Phox employees (including but not limited to their relatives).


Couriers shall immediately notify Phox if any of its employees request or accept, directly or indirectly, any monetary gift or benefit, or products.



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.


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.


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.


Phox complies with all applicable export and import control, sanctions, and customs laws and regulations.


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.


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.


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.


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.



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.


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.


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.


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.



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.


Courier personnel who fail to comply with Phox’s safety rules and regulations may be replaced immediately if requested by Phox.


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:


Identify and control health and safety risks;


Reduce the risk of accidents;


Comply with relevant laws and regulations;


Ensure necessary emergency preparedness and prevention measures are in place; and


Improve overall workplace safety and health performance.


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.



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.


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.


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.



Couriers should contact Phox at or (844) 688-7469 if:


there are any violations of this Code of Conduct;


any requirement to notify Phox under this Code of Conduct is applicable; or


there are any queries on the application or interpretation of the requirements under this Code of Conduct.


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 or (844) 688-7469.