accordance with AIM policy.

4. Conflicts of Interest - Affected individuals must avoid actual, potential, or apparent conflicts between personal interests and their responsibilities to AIM. They may not use their position, confidential information, AIM property, business opportunities, or relationships with people supported, families, vendors, contractors, or referral sources for improper personal benefit or to benefit another person at AIM's expense. Conflicts must be disclosed promptly and managed in accordance with AIM policy. Officers, directors, and any other individuals designated by AIM must complete annual conflict-of-interest disclosures.
5. Business Relationships - Business transactions with vendors, contractors and other third parties will be free from offers or solicitation of gifts and favors in exchange for influence or assistance in a transaction.
6. 5.1 - Gifts and Gratuities - Employees and other affected individuals may not solicit or accept cash, tips, gratuities, gifts, favors, entertainment, or anything of value that could influence, appear to influence, or reward an AIM decision, referral, purchase, service, or business relationship. Items of nominal value may be accepted only when permitted by AIM's conflict-of-interest and gift policies and applicable law. Monetary gifts must be referred to the appropriate administrator or Development Office.
7. 5.2 - Workshops, Seminars, and Training - Attendance at a vendor-sponsored workshop, seminar, conference, or training event must serve a legitimate AIM business purpose and receive any approval required by AIM policy. A vendor may not pay or reimburse travel, lodging, meals, registration, or entertainment unless the arrangement has been reviewed and approved in advance by the Chief Executive Officer or designee.
8. 5.3 - Contracting - Employees may not use insider information for any business activity conducted by or on behalf of AIM. Employees must disclose personal relationships and business activities with contractor personnel which may be construed as influencing the employee's performance or duties.
9. 5.4 - Business Inducement - AIM employees shall not offer, give, solicit or receive any form of bribe or other improper payment.
6. Protection of Assets - All employees will strive to preserve and protect the agency's assets by prudent and effective use of AIM resources and properly and accurately reporting its financial condition. Employees are prohibited from unauthorized use or taking of AIM's equipment, supplies, materials or services.
7. Reporting and Cooperation - Affected individuals must promptly report suspected violations of law, regulation, program requirements, this Code, or AIM policy; suspected fraud, waste, abuse, false claims, or overpayments; retaliation or intimidation; and conduct that threatens the health, safety, rights, or welfare of a person supported. Reports may be made through any channel identified in AIM's Corporate Compliance Program Policy, including anonymously or confidentially where available. Affected individuals must cooperate truthfully with audits, monitoring, investigations, corrective actions, and requests to preserve records. Nothing in this Code restricts lawful communication with a government agency.

VIII. FALSE CLAIMS ACT AND WHISTLEBLOWER PROVISIONS

Federal law requires entities that receive or make at least $5 million in Medicaid payments during a federal fiscal year to maintain written policies for employees, contractors, and agents concerning false-claims laws, whistleblower protections, and procedures for preventing and detecting fraud, waste, and abuse. These entities must include a specific discussion of those subjects in their employee handbook. AIM includes the required discussion in this section and maintains additional procedures in its compliance policies and training materials.