The Code does not tackle every possible ethical or legal issue that you might face. It is vital that you be able to understand our policies, consider the options, and use your own sense of integrity and good judgment. In going through this process, ask yourself the following questions: Will my action comply with the letter and spirit of the Code of Business Conduct? Is this action honest in all respects? Will I be embarrassed if my manager, co-workers, friends or family finds out what I did? Is this action likely to appear inappropriate to others? If you are still uncertain about what to do, discuss the matter with your manager or any of your Compliance Resources. Never engage in prohibited or dishonest acts - even if directed to do so by a manager or co-worker - or direct others to do so. Be sure to report any such requests to any of your Compliance Resources immediately.

Compliance with the Law and Blue Shield Policies Blue Shield and its subsidiaries are subject to an extensive range of federal, state and local laws. These include laws governing confidentiality of medical records, health plan licensing, government contracts and repayment of providers. All employees are expected to comply with these laws, as well as with Blue Shield's Corporate Policies and Human Resources policies. Employees are accountable for asking questions when uncertain about the legality or propriety of particular conduct. If there is a doubt as to the legality of any action, employees should seek advice from any of their Compliance Resources before taking that action.