Surgery Partners : Code of Conduct

Code of Conduct

REVISED: MAY 24, 2021

Code of Conduct

PURPOSE

Surgery Partners is committed to the highest standards of ethics, honesty, and integrity in pursuit of its core values to act with integrity; be accountable; drive clinical and service excellence; demonstrate compassion and kindness; and set and exceed expectations. All Directors, Officers, employees, Partner Physicians, providers, vendors, affiliated entities, business associates, and others who participate in the work and mission of Surgery Partners (collectively Surgery Partners Community Members) are expected to adhere to this Code of Conduct in the discharge of their duties. Consistent with other Surgery Partners policies and procedures, the Code of Conduct provides guidance for the Surgery Partners community and sets forth our commitment to good practices and following the law. Each section of this document has a separate stand-alone policy which can and should be referenced for additional detail.

Notwithstanding any provision of this Code to the contrary, the provisions of this Code shall not be deemed to limit the provisions of the Amended and Restated Certificate of Incorporation of Surgery Partners and, in the event of any conflict, the provisions of the Amended and Restated Certificate of Incorporation shall govern.

Following this Code of Conduct will help you do the right thing. It will also protect you and the Surgery Partners community. You are encouraged to talk with your supervisor if something is not clear, and the Office of Compliance is always available to assist you.

COMPLIANCE WITH THE LAW

Surgery Partners is committed to compliance with all applicable laws, rules, and regulations.

It is the responsibility of Surgery Partners Community Members to follow, in the course and scope of their work at Surgery Partners, all applicable laws, rules, regulations and Surgery Partners policies, as well as federal and state healthcare program requirements and maintain an environment that is committed to integrity and ethical conduct.

All Surgery Partners Community Members are required to report any concerns that may be violations of law, regulation, contract, or policy to the appropriate party. Surgery Partners will take no adverse action, and maintains a policy specifically prohibiting retaliation, against persons who make such reports in good faith.

POLICY # CEP-001 REVISED 5/24/2021

Code of Conduct

PATIENT CARE AND RIGHTS

Our guiding principle at Surgery Partners is that patient care decisions are based on clinical concerns and not business economics.

Only qualified physicians with proper licensure and credentials can practice medicine or surgery at the Company's Facilities.

All medical records and documentation necessary to meet the requirements of medical staff by- laws, policies, accreditation standards, and all laws and regulations will be maintained.

Patients have the right of informed consent. No medical procedure can be performed without the patient's consent. In special situations where the patient is unwilling or unable to consent to treatment, the Surgery Partners employee should consult with Surgery Partners Chief Compliance Officer.

CONFIDENTIALITY

Surgery Partners is committed to the appropriate protection of confidential information.

Federal and state laws and Surgery Partners policies prohibit the unauthorized seeking, disclosing or giving of confidential information, contained in patient, research, employee or business records. All Surgery Partners Community Members are required to know and comply with laws and policies related to information privacy and security. Confidential information includes all financial, patient and other records and non-public information that, if disclosed, might be of use to competitors, or harmful to Surgery Partners, its partners or patients.

All Surgery Partners Community Members are required to complete confidentiality training and agree to abide by its content. Confidential information is to be accessed, used, and disclosed only when authorized or required by law and required to complete assigned job duties. User IDs, passwords, and other authentication devices are the equivalent of a signature within the information systems and must be safeguarded and never shared or disclosed. Surgery Partners Community Members are required to know and comply with laws and policies related to information privacy and security.

POLICY # CEP-001 REVISED 5/24/2021

Code of Conduct

DISCRIMINATION

Surgery Partners is committed to the principles of diversity and equality and will not discriminate.

Surgery Partners does not discriminate against individuals on the basis of their race, sex, religion, color, national or ethnic origin, age, disability, sexual orientation, gender identity, gender expression, military service, pregnancy, physical or mental disabilities, genetic information,

or any other class protected by applicable law in its administration of policies, programs or employment.

HARASSMENT

Surgery Partners prohibits harassment of any kind.

Surgery Partners strictly prohibits harassment or contribution to any type of harassment. This includes, but is not limited to, sexual harassment or misconduct, treating colleagues in a disrespectful manner, retaliation, or bullying. Everyone is encouraged to report if they witness any type of harassment.

CONFLICTS OF INTEREST

All Surgery Partners Community Members should avoid potential or perceived conflicts of interest.

A "conflict of interest" occurs when an individual's private interest interferes in any way, or even appears to interfere, with the interests of Surgery Partners as a whole. A conflict situation can arise when a Surgery Partners Community Member takes actions or has interests that may make it difficult to perform his or her work for Surgery Partners objectively and effectively. Conflicts of interest also arise when a Surgery Partners Community Members, or a member of his or her family, receives improper personal benefits as a result of his or her position in or with Surgery Partners. Loans, guarantees or obligations to Surgery Partners Community Members or family members are of special concern, and must comply with all laws and may be subject to approval by the Audit and Compliance Committees of the Board of Directors.

Any Surgery Partners Community Members who becomes aware of a conflict or potential conflict of interest or any material transaction or relationship that reasonably could be expected to give rise to a conflict of interest should bring it to the attention of a supervisor, manager or the Chief Compliance Officer.

POLICY # CEP-001 REVISED 5/24/2021

Code of Conduct

PUBLIC DISCLOSURE SHOULD BE FULL, FAIR, ACCURATE, TIMELY AND UNDERSTANDABLE.

Directors, officers and employees who are involved in the preparation of reports and documents that Surgery Partners files with or submits to the Securities and Exchange Commission or that are otherwise public communications have a responsibility to promote full, fair, accurate, timely and understandable disclosure in such reports, documents and communications. Such persons shall act in accordance with Surgery Partners Disclosure Controls and Procedures Manual.

PROHIBITION FROM TAKING SURGERY PARTNERS CORPORATE OPPORTUNITIES

Surgery Partners is committed to prohibiting the taking of Surgery Partners corporate opportunities for improper personal gain.

Surgery Partners Community Members are prohibited from (a) taking for themselves opportunities that are discovered through the use of Surgery Partners' property, information or position, without the consent of a majority of the disinterested members of the Board of Directors, (b) using Surgery Partners' property, information or position for improper personal gain or (c) competing with Surgery Partners directly or indirectly. Directors, officers and employees owe a duty to Surgery Partners to advance its legitimate interests when the opportunity to do so arises.

FAIR DEALING IN ALL ACTIVITIES

Surgery Partners is committed to fair dealing in all activities.

Surgery Partners Community Members should endeavor to deal fairly with Surgery Partners' partners, employees, competitors, customers and suppliers. Surgery Partners Community Members should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair-dealing practice in connection with Surgery Partners' business.

POLICY # CEP-001 REVISED 5/24/2021