Corporate Independence Policy

David Donn Consulting, Inc. (DDC) operates under a core principle of transparent objectivity, meaning DDC is committed to providing unbiased opinions, research and analysis that is singularly aligned with the interests of our clients. To ensure the practice and continuance of this principle, DDC enforces the following corporate financial guidelines:

MANAGED CARE COMPANY (MCC) CLIENT RESTRICTION: DDC does not enter into client relationships with or accept engagements from companies that directly provide workers' compensation managed care cost containment services, including medical bill review, PPO, utilization review and case management services.

FINANCIAL INDEPENDENCE: In the course of client engagements and general research processes, DDC representatives often interact with MCC's and their representatives. As a fundamental guideline, DDC representatives do not accept any direct or indirect compensation from MCC's. Specifically, DDC employees do not accept any of the following:

• any meals or entertainment compensation
• any direct financial considerations to employees, their friends or family
• any securities or financial instruments of any type
• any travel expense reimbursements
• any gifts exceeding $25 in value (gifts under $25 in value are donated to local charities)

CONFLICT OF INTEREST: All DDC employees are restricted from holding any securities or financial interests in companies or organizations that directly provide workers' compensation managed care cost containment services, including the equities, bonds, warrants, etc. of any public or private entity providing one or more of the cost containment services researched by DDC, unless held through shares of a mutual fund or other similar composite security.