Hugo’s Code of Business Conduct                           

How to Use the Code of Business Conduct

The Hugo Code of Business Conduct summarizes the regulatory requirements and business practices that guide our decision making and business activities. The Code contains basic information about our policies as well as information about how to obtain guidance regarding a particular business practice or compliance concern. It is essential that you thoroughly review this publication and make a commitment to uphold its requirements.

The Code of Business Conduct is not intended to cover every issue or situation you may face as a Hugo team member. Nor does it replace other more detailed policies. You should use the Code as a reference guide in addition to Hugo policies, including the Team Handbook, required for your specific job.  Hugo reserves the right in its sole discretion to modify or eliminate any of the Code’s contents without prior notice. 

If you need guidance regarding a business practice or compliance issue, or if you want to report a possible violation, talk to your immediate supervisor, manager or another member of the management team. Hugo will handle all inquiries discreetly and preserve confidentiality of anyone requesting guidance or reporting a possible violation to the extent possible and within the limits allowed by the law.

Hugo’s Values

Hugo Health (referred to as Hugo) is motivated by commonly held principles and values that allow us to work toward mutual goals. The core of these values is that Hugois a company of honesty and integrity. This philosophy is fundamental to our ability to attract and retain the best people, gain and keep the trust of our customers and our partners, support the communities in which we operate, and protect our reputation.

Our values guide our behaviors and our interactions. The same core values apply internally in our work environment and externally to customers and all others we interact with. Hugo team members are great people who share the following values:

  •  Integrity: Our actions, measures and principles are practiced consistently and ethically.

  • Innovation: We are forever finding methods and ideas that lead to productive growth. 
We embrace change and seek to deliver it.

  • Discipline: Focus and commitment makes our company stronger.

  • Commitment: To those we work with and all those we serve, we are dedicated to the goals we set out to achieve.

  • Compassion: We act with kindness and generosity knowing that caring for and being interested in others helps us live more compassionate lives.

It has always been, and continues to be, our policy to conduct business in compliance with all applicable laws and regulations and in accordance with the highest ethical standards. The Hugo Code of Business Conduct is applicable to all our team members, suppliers, their subcontractors and other business partners that do business with Hugo. We expect that Hugo team members, and the people acting on our behalf, will adhere to these principles.

Statement of Policy

Hugo manages business in compliance with all applicable laws and regulations of any country in which we operate, and in accordance with our company's Code of Business Conduct. All team members are expected to comply with the Hugo Code of Business Conduct, which is essential to maintaining our reputation for honesty, quality, and integrity. It is also each team member’s responsibility to report to the company any situation where our Code or the laws are being violated. Any team member disclosing, in good faith, violations or suspected violations of legal requirements or Hugo Code of Business Conduct will not be subjected to retaliation or retribution. Likewise, failure to comply with the provisions of the Hugo Code of Business Conductwillnot be tolerated. 

This Code of Business Conduct sets forth our code of conduct for all Hugo team members. Throughout the Code, "Hugo" is used to refer to the enterprise as a whole, to each person within it, and to any person who represents Hugo or any part of the Hugo organization.

Personal Responsibility: All team members are required to abide by all applicable governmental laws, rules and regulations, Hugo policies, including this Code, and all other Codes of ethical conduct.  In addition, team members must promptly report any violation of such laws, rules, regulations and policies to an appropriate person within the company.

Managerial Responsibility: Managers (defined as team members who supervise others) are expected to exemplify the highest standards of ethical business conduct. Managers are responsible for creating a work environment that promotes honest and ethical behavior and are expected to be familiar with the policies and legal requirements applicable to our organization to ensure all team members receive appropriate training and guidance.   

Managers must be diligent in discovering unethical or illegal conduct and must promptly take corrective or disciplinary action when misconduct is substantiated.   

Discipline:Team members who violate Hugo policy, including this Code, may be subject to disciplinary action up to and including termination. Team members who commit criminal acts may be subject to immediate termination and/or possible civil or criminal prosecution. Obstructing or undermining investigations, withholding or destroying information, including failing to report a violation, or providing misleading information are violations of this Code.  

No Retaliation: Hugo forbids retaliation against any team member who, in good faith, reports a suspected violation of law or policy, including harassment or discrimination. This includes blatant actions, such as firing, transferring, demoting or publicly attacking someone, as well as more subtle retaliation, such as avoiding someone, leaving him or her out of professional or social activities and so on. It includes actions taken by all team members.

Any person involved in retaliation will be subject to disciplinary action up to and including discharge.

Laws and Regulatory Requirements

Integrity: Hugo team members interact with a variety of individuals and groups—including our customers, competitors, co-workers, suppliers, government and regulatory agencies, and the communities in which we operate. We are committed to interacting with all of these audiences in a respectful, ethical manner and in compliance with applicable laws and regulatory requirements.

Regulatory Compliance: We are aware of and obey the laws and regulations that govern the management of our business. We are responsible for understanding these laws and regulations as they apply to our jobs and for preventing, detecting, and reporting instances of non-compliance to a member of Hugo management.

Regulatory Investigations, Inspections, and Inquiries: We are direct, honest, and truthful in our discussions with regulatory agency representatives and government officials. During investigations, inspections, and inquiries we will fully cooperate by responding to appropriate requests for information.

International Business Activities: Hugo acknowledges and respects the diverse cultures, customs, and business practices it encounters in the international marketplace. Hugo will comply with both the applicable U.S. laws and regulations that govern its operations and local laws wherever it does business.

Bribery and Anti-Corruption: Hugo prohibits corruption of government officials and the payments of bribes or kickbacks of any kind, whether in dealings with public officials or individuals in the private sector. Hugo is committed to observing the Code of Conduct set forth in the United States Foreign Corrupt Practices Act and the applicable anti-corruption and anti-money laundering laws of the countries in which we operate.

Anti-Boycott Requirements: Hugo complies with U.S. law that prohibits participation in international boycotts that are not sanctioned by the U.S. government. 

Trade Controls: Hugo is committed to maintaining compliance with all laws and regulations governing the import, use, export and re-export of its products, services and technical data. 

Fair Competition and Antitrust: Hugo encounters laws and regulations designed to promote fair competition and encourage ethical and legal behavior among competitors. Antitrust laws and fair competition laws generally prohibit any activity that restrains free trade and limits competition. We conduct our business in compliance with these laws.

Internal Controls: Hugo believes reliable internal controls are critical for proper, complete and accurate accounting and financial reporting. All team members must understand the internal controls relevant to their positions and follow the policies and procedures related to those controls. Team members are strongly encouraged to talk to their managers or supervisors immediately if they ever suspect that a control does not adequately detect or prevent inaccuracy, waste or fraud.

 Audits: Hugo believes that audits performed by internal and external auditors help ensure compliance with established policies, procedures and controls. Audits also help identify potential weaknesses so they may be remediated promptly. Every team member is required to cooperate fully with internal and external audits. This means always providing clear and truthful information and cooperating fully during the audit process.

 Fraud: Engaging in any scheme to defraud anyone —of money, property or honest services — violates

Company policy and the law and carries severe penalties. Those consequences apply to any dishonest or fraudulent activities, including misusing or stealing Company assets or falsifying a travel and entertainment expense report, among other violations. Hugo relies on its internal controls and the personal integrity of all its team members, contractors and directors to protect Company assets against damage, theft and other unauthorized use.

 Reporting Possible Violations: Hugo expects any team member to speak up promptly if there is any reason to suspect that anyone at Hugo or in any company in the supply chain has violated Company policies and/or local laws. Team members must also report any activity that could damage the Company’s reputation to their supervisor or anyone in management. 

Trust and Respect 

Responsible Leadership: We manage our business responsibly in order to maintain the confidence, respect, and trust of our team members, customers, consumers, partners, and stakeholders. We are committed to acting with integrity, being responsive and accountable to our team members, customers and partners, and remaining a leader in our field. 

Product and Service Quality: Hugo products are developed to meet the expectations of our customers, consumers, and partners for high quality and exceptional service. We continually seek new ways to improve our products, service, and responsiveness.

Communication: We apply full, fair, accurate, timely, and understandable disclosure in reports and documents that are required by state and/or federal laws and in other public communications as well. We establish and maintain clear, honest, and open communications; listen carefully; and build our relationships on trust, respect, and mutual understanding. We are accountable and responsive to the needs of team members and customers and take our commitments to them seriously. Our advertising, sales, and promotional literature seeks to be truthful, accurate, and free from false claims.

Obtaining Competitive Information: Hugo has an obligation, and is entitled, to keep up with developments in our industry, including obtaining information about our competitors. We obtain information about our competitors through honest, ethical, and legal methods.

Fair Information Practices: Our business uses technology to manage information, and we treat that information with confidentiality and integrity.  We have adopted privacy practices and operate in a manner that complies with local, state and federal privacy laws.

Customer Relations: We compete fairly and in accordance with the Code of Business Conduct in all of our customer relationships. We want to earn business on the basis of superior services and products and competitive prices, not through improper, unethical, or questionable business practices.

Our credibility with our customers depends on our ability to fulfill our commitments. Any time we fail to live up to a commitment, hard-earned customer trust is damaged.

To preserve our customer relationships:

  • We do not misrepresent our services or products in any sales or promotional efforts. 

  • We communicate clearly, so that our customers understand the terms of our business relationships, including contracts, performance criteria, schedules, prices, and responsibilities. 

  • We protect our customers' confidential information. 

  • We only make promises to customers that we believe we will be able to keep.

Doing Business with the Government: Doing business with the government is not always the same as doing business with private parties. Activities that might be appropriate when working with private sector customers may be improper, or even illegal, when a national or local government is our customer. For example, business courtesies or entertainment that might be acceptable when dealing with private parties, like paying for meals or drinks, may not be appropriate when working with government officials. In addition, due to complex legal requirements, some types of bid-related information, which might be proper in a transaction with a private party, may not be requested or received when dealing with governments or their officials.

Choosing Suppliers and Consultants: Hugo strives to be fair in our choice of suppliers and consultants and is honest in all business interactions with them. We choose our suppliers and consultants based on appropriate criteria, such as qualifications, competitive price, and reputation. Anyone responsible for buying or leasing materials or services on behalf of Hugo must conscientiously guard their objectivity.

We also expect our suppliers and consultants, and others who do business with us or on our behalf, to conduct their business on behalf of Hugo in compliance with all applicable laws and regulations and in accordance with the highest ethical standards. Suppliers are expected to provide high-quality services and products while maintaining flexibility and cost-effectiveness. All suppliers are required to train their team members and representatives to ensure that they are aware of expectations regarding their behavior. We do not engage in any unethical or illegal conduct with our suppliers. We do not accept incentives such as kickbacks or bribes in return for conducting business with them.

Company Assets

Financial Integrity: Hugo honestly and accurately records and reports business information. We comply with all applicable local, state, and federal laws regarding record completion and accuracy. We require that financial transactions be executed in accordance with management's authorization and recorded in a proper manner in order to maintain accountability for Hugo assets. Our financial information reflects only actual transactions and is in compliance with all applicable local, state and federal laws. 

Use and Protection of Assets: Hugo wisely uses and protects the assets of the Company, including property (both physical and intellectual), supplies, consumables, and equipment. These assets are used exclusively for Hugo business purposes.

Fiscal Responsibility: Hugo team members exercise good stewardship over and spend Hugo funds in a responsible manner.

Use of Information Technology: At all times, we strive to use good judgment and common sense; conduct ourselves ethically, lawfully, and professionally; and follow applicable authorization protocols while accessing and using Company-provided information technology and its contents. In using these Company assets and systems, we do not create, access, store, print, solicit, or send any material that is intimidating, harassing, threatening, abusive, sexually explicit, or otherwise offensive or inappropriate, nor do we send any false, derogatory, or malicious communications.

Intellectual Property: Hugo complies with the laws and regulations that govern the rights to and protection of our own and others' copyrights, trademarks, patents, trade secrets, and other forms of intellectual property.

Creation, Retention, and Disposal of Records and Information Assets: Hugo creates, retains, and disposes of our business records and information assets, both written and electronic, as part of our normal course of business in compliance with Hugo policies and applicable regulatory and legal requirements.

Confidential and Proprietary Information:  All team members have ethical and legal responsibilities to protect Hugo confidential and proprietary non-public information and communicate it only as necessary to conduct Hugo business. Team members do not use this information for personal advantage or for non-Hugo business use and maintain this confidentiality even after leaving Hugo’s employment.

Third-Party Software:  Software and other content information is used only in accordance with their associated licenses and/or terms of use. Hugo prohibits the making or using of copies of non-licensed copyrighted material, including software, documentation, graphics, photographs, clip art, animation, movie/video clips, sound, and music.

Insider Information and Securities Trading: In the course of doing business for Hugo or in discussions with one of its customers, suppliers, or partners, we may become aware of material non-public information about that organization. Information is considered "material" if there is a substantial likelihood that a reasonable investor would consider it important in making a decision to trade in the public securities of the company. Individuals who have access to this type of information are called "insiders." This information is discussed on a limited, "need to know" basis internally, and is not shared with anyone outside of Hugo. We do not buy or sell the public securities of a company on the basis of such information, and we do not share ("tip") this information with others. 

Purchasing Decisions and Practices: In our purchasing decisions, negotiations, contract development, and contract administration Hugo complies with the applicable laws and regulations that govern those relationships. 

Our People

Openness, Honesty, and Respect: In our relationships with each other, we strive to be open, honest, and respectful in sharing our ideas and thoughts, and in receiving input.

Diversity: Hugo promotes and supports a diverse workforce at all levels of the Company.It is our belief that creating a work environment that enables us to attract, retain, and fully engage diverse talents leads to enhanced innovation and creativity.

 Hugo values and demonstrates respect for the uniqueness of individuals and the varied perspectives and talents they provide. Hugo has an inclusive work environment and actively embrace a diversity of people, ideas, talents and experiences.

 Equal Opportunity: Hugo is an Equal Opportunity/Affirmative Action Employer. Hugo has an ongoing commitment to a diverse workplace free of discrimination and harassment.  Hugo recruits, hires, trains, and promotes individuals in all job titles without regard to race, color, creed, religion, ancestry, sexual orientation, genetic information, gender identity, national origin, age, sex, physical or mental disability, being a disabled veteran, veteran of the Vietnam era, or other eligible veteran. At Hugo, we are committed to a fair and equitable workplace.

It is the policy of Hugo to comply with all applicable discrimination laws – defined here as including (but not limited to) all provisions of all current federal and state employment statutes, local ordinances, as well as their respective implementing regulations and related case law, the Acts for Civil Rights, Equal Employment Opportunity (EEO), Americans With Disabilities Act (ADA), Genetic Information Nondiscrimination Act (GINA), Age Discrimination in Employment, Equal Pay and Fair Labor Standards.

Hugo is committed to equal employment opportunity in all employment facets for all team members and applicants for employment without regard to their membership in Protected Classes. 

All managers and supervisors will take an active part in the Company's affirmative action commitment to ensure that all team members and applicants for employment are considered and treated in a nondiscriminatory manner with respect to all employment decisions. Furthermore, Hugo will solicit the cooperation and support of all team members for the Company's nondiscrimination policy.

There shall be no discrimination, harassment and/or retaliation against any individual or group of individuals on the basis of belonging to, or being perceived as belonging to, a Protected Class in Company policies, programs, services, activities, practices, terms, privileges, benefits or conditions, 

In employment and providing services to the disabled, Hugo will make reasonable accommodations as required for all team members, applicants or citizens with a disability, provided that the individual is otherwise qualified to safely perform the essential functions connected with the job and provided further that any accommodations made would not require undue hardship on the Company. 

Hugo is committed to providing opportunities to address all issues relating to workplace discrimination, harassment or retaliation. Hugo recognizes that workplace issues must surface early in order to minimize the direct and indirect costs of discrimination, harassment or retaliation. Hugo takes allegations of harassment and unlawful discrimination seriously and addresses any concerns that are raised regarding this policy.

Accommodating Individuals with Disabilities: Hugo does not discriminate against any qualified team member or job applicant with respect to any terms, privileges, or conditions of employment because of such individual's disability or perceived disability so long as the individual has the knowledge and skills to perform the essential functions of the job effectively with or without reasonable accommodation. Consistent with this policy of non-discrimination, Hugo will provide reasonable accommodations to a qualified individual with a disability, as defined by applicable law, who has made the Company aware of his or her disability, provided that such accommodation does not constitute an undue hardship on the Company. Team members with a disability who believe they need a reasonable accommodation to perform the essential functions of their job should promptly contact Human Resources. 

A team member or job applicant who has questions regarding this policy or believes that he or she has been discriminated against based on a disability should promptly notify management. All such inquiries or complaints will be treated as confidential to the extent practical under the circumstances. Team members may raise their good faith complaints of illegal discrimination without fear of reprisal.

Marital Status & Pregnancy Discrimination: Hugo prohibits discrimination based on marital status, pregnancy, childbirth or other related conditions, including breastfeeding or expressing milk at work, and prohibits following actions:

  • Refusing to hire a woman because she is pregnant; 

  • Forcing a pregnant team member to leave work if she is willing and able to work;

  • Terminating a woman’s employment because of her pregnancy;

  • Refusing to grant a team member a reasonable leave of absence for disability resulting from her pregnancy;

  • Denying a team member, who is disabled as a result of pregnancy, any compensation to which she is entitled as a result of the accumulation of disability or leave benefits accrued pursuant to plans maintained by the employer;

  • Failing to reinstate the team member to her original job or to an equivalent position with equivalent pay and accumulated seniority, retirement, fringe benefits and other service credits upon her signifying her intent to return unless, the employer’s circumstances have so changed as to make it impossible or unreasonable to do so.

  • Limiting, segregating or classifying a pregnant team member in a way that would deprive her of employment opportunities due to her pregnancy;

  • Discriminating against a team member or person seeking employment on the basis of her pregnancy in the terms or conditions of her employment;

  • Failing to make a reasonable accommodation for a team member or person seeking employment due to her pregnancy, unless the employer can demonstrate that such accommodation would impose an undue hardship on such employer;

  • Denying employment opportunities to a team member or person seeking employment if such denial is due to the team member’s request for a reasonable accommodation due to her pregnancy;

  • Forcing a team member or person seeking employment affected by pregnancy to accept a reasonable accommodation if such team member or person seeking employment does not:

    • Have a known limitation related to her pregnancy; or  

    • Require a reasonable accommodation to perform the essential duties related to her employment.

  • Requiring a team member to take a leave of absence if a reasonable accommodation can be provided in lieu of such leave; 

  • Denying reasonable leave of absence for disability due to pregnancy (e.g., doctor prescribed bed rest during 6-8 week recovery period after birth); 

  • Denying disability or leave benefits accrued under plans maintained by the employer; and

  • Retaliating against a team member in the terms, conditions or privileges of her employment based upon such team member’s request for a reasonable accommodation.

“Reasonable accommodation” means, “but shall not be limited to, being permitted to sit while working, more frequent or longer breaks, periodic rest, assistance with manual labor, job restructuring, light duty assignments, modified work schedules, temporary transfers to less strenuous or hazardous work, time off to recover from childbirth or break time and appropriate facilities for expressing breast milk.”

“Undue hardship” means an action requiring significant difficulty or expense when considered in light of factors such as (A) the nature and cost of the accommodation; (B) the overall financial resources of the employer; (C) the overall size of the business of the employer with respect to the number of team members, and the number, type and location of its facilities; and (D) the effect on expenses and resources or the impact otherwise of such accommodation upon the operation of the employer.

A team member may not be retaliated against because of a request for reasonable accommodation.

Gender & Pay Equity: Hugo is committed to ensuring there is no gender-based wage discrimination within the practice. Hugo’s goal is to ensure that women are treated on the same basis as men in terms of opportunities and compensation for the work they perform. All team members performing the same or similar work of equal value will be compensated on the same pay scale.

Hugo meets or exceeds legislated wage requirements and compensates team members performing the same or similar work, or work of equal value, regardless of gender.

 Sexual & Unlawful Harassment: All team members are guaranteed the right to work in an environment free from unlawful workplace harassment and retaliation. Hugo will thoroughly investigate all complaints made by team members and will take appropriate remedial or disciplinary action up to and including dismissal. Prohibited unlawful workplace harassment includes unwelcome or unsolicited speech or conduct based upon race, marital status, sex (including pregnancy), gender identification/expression, genetic information, creed, religion, national origin, age, color, physical disability or mental disability and which creates a hostile work environment or constitutes quid pro quo sexual harassment.

Workplace Health & Safety: The health and safety of our people are of utmost importance toHugo and the company is committed to protecting the health and well-being of every team member. We strive to protect our people, customers, and the public from injury and illness. Hugo actively promotes the health and safety of its team through compliance with applicable laws and regulations. Hugo expects its team members to support this commitment by complying with all Hugo practices, rules and regulations regarding safety and by actively striving to identify opportunities for improvement in Hugo’s health and safety programs. 

Team members are required to advise the company of any workplace injury, instance of non-compliance, or any situation presenting a danger of injury as soon as possible. This information will assist in preventing injuries and will ensure that appropriate medical attention is provided. Through investigation of such reports, we can identify contributing factors and determine if our policies and processes are effective and adequately communicated. When an unsafe condition, practice, or non-compliant action is identified, prompt and appropriate action must be taken to correct the condition and prevent it from happening again.

Drug and Alcohol Policy: It is Hugo’s policy to maintain a drug-free and alcohol-free work environment.  Use of alcohol and/or illegal drugs creates serious health and safety risks in the workplace.  The use, sale, or possession of alcohol, illegal drugs, or other illegal substances is strictly prohibited while at work, on Company property, or while on Company business. This prohibition also includes illegal or improper use of controlled substances.

Reporting to work under the influence of any such substance is strictly prohibited.  No one is permitted to go on duty or remain on duty if they possess or have the presence of an illegal or unauthorized controlled substance or alcohol in their system. Team members are not permitted to go on duty or remain on duty if they are impaired by the presence of an authorized controlled substance.  In addition, Hugo complies with all laws and regulations regarding the use or possession of alcohol, illegal drugs, and controlled substances.

Workplace Violence Prevention: Hugo is committed to a safe working environment, free of threats, intimidation and physical harm.  Everyone has a right to work in a safe environment and shares the responsibility for assuring each other's safety.  Hugo has adopted a zero-tolerance workplace violence policy. This means we will investigate and take appropriate action against any threat to a safe workplace.

Hugo prohibits violent behavior including, but not limited to, physical assaults, fighting, threatening comments, intimidation, and the intentional or reckless destruction of company, team, or customer property. Any comments or behavior that reasonably could be interpreted as intent to do harm to people or property will be considered a threat.  We also prohibit the unauthorized possession and/or use of weapons by any team member while at work, on Company property, or while on Company business.

Any team member who believes that he or she may be the target of violence or threats of violence, or is aware of violent or threatening conduct by, or directed at, a Hugo team member that could result in injury to a person or the destruction of property, has a responsibility to immediately report the situation to his or her immediate supervisor or any member of management.

Conflicts of Interest: All team members areexpected to give our undivided business loyalty to Hugo when conducting our job-related duties. Accordingly, team members must be careful to avoid conflicts of interest - situations where private interests conflict, or even appear to conflict, with the interests of Hugoas a whole. Therefore, team members should not place themselves in situations that might force them to inappropriately choose between their own personal or financial interests and the interests ofHugo.  

Conflicts of interest can arise in many common areas, despite best efforts to avoid them. However, such conflicts can generally be resolved by promptly notifying your manager of any actual, perceived, or potential conflict of interest situation. The manager can then provide guidance on how best to resolve the conflict. 

Doing Business with the Company: A conflict of interest could arise if a team member, a spouse, a relative, or a close personal friend, has a personal stake in a business that supplies or seeks to supply goods or services to Hugo, is a Hugo customer or potential customer, or competes with Hugo.   Accordingly, the following Code applies in such situations:

  •  If a Hugo team member, spouse, relative, or close personal friend is a team member of, or has a significant interest in a business that provides or is seeking to provide goods or services to Hugo, the Hugoteam member must not attempt to use his or her position with Hugo to influence the bidding process or negotiation in any way. Similarly, the Hugo team member must not use personal relationships to improperly influence dealings with a customer or a potential customer. 

  • If the position of a relative or friend who works for a competitor is such that a potential conflict of interest could arise, the Hugo team member should seek guidance from a manager.

Gifts and Entertainment: All team members and representatives of Hugo should understand the legal and ethical issues associated with gifts and entertainment and how they can affect our relationship and reputation with our customers, suppliers, and the general public. The decision to offer or to accept gifts or entertainment should be made only in compliance with legal requirements and ethical considerations, and with the involvement of a manager if unsure of the appropriate course.

Hugo encourages the use of good judgment, discretion, and moderation when giving or accepting gifts or entertainment in business settings. Any gifts and entertainment given or received must be in compliance with law, must not violate the giver's and/or receiver's policies on the matter. We do not solicit gifts, entertainment, or favors of any value from persons or firms with which Hugo actually or potentially does business. Nor do we act in a manner that would place any supplier or customer in a position where he/she may feel obligated to make a gift, provide entertainment, or provide personal favors in order to do business or continue to do business with Hugo.   

The issue of gifts and gratuities may have legal implications when the government, or government entity is involved, and serious consequences can result from mishandling these relationships. Offering or accepting bribes and pay-offs is always prohibited.

Business gifts and entertainment are courtesies designed to build goodwill and sound working relationships among business partners. We do not, however, want to obtain business through improper means as to gain any special advantage in a relationship. Business gifts that compromise, or even appear to compromise, our ability to make objective and fair business decisions are inappropriate.

Solicitation of gifts is never appropriate, even for charitable purposes. All gifts and entertainment, other than infrequent items of nominal value, must be disclosed to a manager.

Employment Outside of Hugo: Although employment outside of Hugo is not necessarily a conflict of interest, depending upon an individual's position with Hugo and Hugo’s relationship with the other organization, a conflict could arise. Outside employment also could be a conflict of interest if it causes, or might be perceived by others to cause, a team member to choose between that interest and the interests of Hugo. If a situation arises, either through scheduling or other potential conflicts, our undivided business loyalty requires that we resolve the conflict in favor of Hugo. 

In some cases, Hugo team members may be involved in outside businesses that are not Hugo competitors or suppliers. These situations do not necessarily constitute a conflict of interest, but it is the team member’s responsibility to ensure that these activities do not conflict with Hugo’s interests.

This requires keeping the two activities strictly separated by adhering to the following standards. A Hugo team member:

  • May not do work relating to other organizations on Hugo time; 

  • May not use Hugo equipment and supplies, or the time of any Hugo personnel for outside work; 

  • May not promote products or services from an outside business to other Hugoteam members during working hours or on Hugo property;

  • May not attempt to sell products or services from an outside business to Hugo; and   

  • May not use his or her position in the Company to promote an outside business. 

Employment At Will: Hugo team members are considered to be “at will.” At-will employment means that a team member has the right to terminate their employment with the Company at any time, for any reason or for no reason. Similarly, the Company has the right to terminate the team member’s employment at any time, for any reason or for no reason. 

No representative of the Company, other than the CEO or the Founder of the Company, has the authority to enter into any agreement for a specified period of time or to make any agreement at any time during an team member’s employment with the Company that purports to guarantee a specific term or condition of employment or to alter the at-will policy. Any such agreement is only valid if it is by individual agreement, in writing, and is signed by the team member and by the CEO.

Our Community

Political Activities and Contributions: Hugo encourages all team members to be informed voters, but personal participation in the political process, including contributions of time or financial support, is completely voluntary.

Environmental Protection: Hugo is committed to conducting business in a manner that protects the environment. Our commitment to the environment goes beyond complying with environmental laws and includes a commitment to advancing programs that promote improvement of the environment. 

Our environmental responsibilities include:

  • Properly storing, handling, and disposing of hazardous and other waste; 

  • Managing wastewater and storm water in compliance with applicable regulations; 

  • Complying with laws regarding clean air; 

  • Protecting against and appropriately responding to spills and releases; and 

  • Seeking ways to minimize waste, recycle, reduce energy consumption and prevent pollution.

In addition, Hugo must provide timely, truthful, and accurate information required in connection with applications for environmental permits and other reports called for under permits or regulatory requirements.

Prohibition Against Human Trafficking: Hugo condemns all forms of human trafficking and commercial exploitation, including the sexual exploitation of men, women or children. Hugo is committed to a work environment that is free from human trafficking, forced labor and unlawful child labor. Hugo requires its supply chain partners to observe the law and conduct business in an ethical and responsible manner. 

 Freely Chosen Employment: Forced, bonded or indentured labor or involuntary prison labor shall not to be used.All work will be voluntary, and team members shall be free to leave. Team members shall not be required to hand over government-issued identification, passports or work permits as a condition of employment. 

Child Labor Avoidance: The term “child” refers to any person under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Team members under the age of 18 shall not perform work that is likely to jeopardize their health or safety. 

Citizenship and Community Service: Hugo has a strong and demonstrated commitment to the improvement of society as well as the communities we serve and in which we operate. We encourage the support of charitable, civic, educational, and cultural causes. 

How to Suggest Changes to the Code of Business Conduct

If you have any suggestions for changes to the Hugo Code of Business Conduct, please submit them promptly, as indicated below, while they are fresh in your mind. This form is included for your convenience in submitting recommendations for changes. If you prefer, you may use your own words, stationary, and format. Please submit suggestions admin@hugo.health.

I recommend the following change(s) be made in the Hugo Code of Business Conduct

Section on page ________




Hugo’s Code of Business Conductis not an express or implied contract of employment and does not create any contractual rights of any kind between Hugo and its team. In addition, all team members should understand that their employment at Hugo is “at will” and that the Code of Business Conductdoes not modify this employment relationship. This Codeis intended to clarify each team members existing obligation for proper conduct. Hugo reserves the right in its sole discretion to modify or eliminate the Code at any time for any reason without prior notice.


Code of Business Conduct Acknowledgement Form

I have received, read and understand the Code of Business Conduct.

I understand that Hugo’s Code of Business Conductisnot an express or implied contractof employment and does not create any contractual rights of any kind betweenHugo and itsteam. In addition,I understand that I work at Hugo “at will”, meaning that I am free to leave Hugo at any time, with or without reason, and that the company has the same right to terminate my employment andthat the Code of Business Conductdoes not modify my employment relationship. 

I understand this Codeis intended to clarify each team member's existing obligation for proper conduct. 

I understand that if I have knowledge, either direct or indirect, of a possible violation of this Code I am obliged to report the circumstances immediately to my supervisor or to another manager.

I understand Hugo reserves the right in its sole discretion to modify or eliminate the Codeof Business Conduct at any time for any reason without prior notice.

I understand I should consult with Leslie Krumholz regarding any questions I may have about Hugo’s Code of Business Conduct.


Team Member Signature: ______________________________

Team Member Name Printed: ___________________________

Date: ________________