Honesty and ethical behavior have always played an important role in the work of the Occupational Development Center, Inc. (“ODC” or “Company”). Our operations involve important legal and ethical responsibilities. These responsibilities extend to the consumers, guardians and families of our program, to the many companies and public and private agencies we work with, to our fellow workers and employees and to the public at large. It has always been the policy of ODC that its team members, consumers, directors, officers, associates, representatives and agents (collectively referred to herein as “Employees”) should behave in an ethical and lawful manner and comply with all relevant laws, rules and regulations. Our business should be conducted in accordance with the highest ethical standards.

The Corporate Compliance Program (the “Compliance Program”) operates under the authority of the President/CEO and the Board of Directors of ODC and applies to all Employees of ODC. The Compliance Program has been carefully designed to assure that ODC acts in accordance with all known legal duties. The highest standards of ethical conduct are expected of all Employees. No Employee may disregard any requirement of this Compliance Program. The Compliance Program is meant to provide an effective means for preventing and detecting potential compliance problems before they happen and to make it possible for everyone affiliated with ODC to report concerns about business practices without fear of retribution.