Laboratory of America : Code of Conduct & Ethics

Courage

10 What Do I Do If I Know About or Suspect a Violation of the Code?

1. How Do I Report a Violation?
2. What Happens When I Report?

1. No Retaliation

Teamwork

1. Equal Opportunity Employment

1. No Discrimination or Harassment
2. Substance Abuse and Treatment

1. Background and Exclusion Checks

1. Anti-Violence

Integrity

1. Securities Regulation - Insider Trading

1. Securities Regulation - Rules for Principal Executive Officer and Senior Financial Officer
2. Preventing Bribery, Corruption and Improper Influence
3. Quality

26 Trade Compliance

Inspiration

1. Human Rights
2. Public Service and Political Contributions

1. Environment, Health and Safety
2. Waivers of or Changes in The Code of Conduct and Ethics

30 Administration

30 Contacts and Resources

Labcorp holds itself to the highest ethical standards and expects you to read, understand and abide by those standards and this Code. This Code of Conduct and Ethics (Code) is not simply a list of rules; it is a statement of our fundamental values, intended to serve as a guide to help us make the right choices and decisions consistent with the highest ethical standards. This Code serves as a roadmap incorporating our values into the decisions we each make every day.

Labcorp uses cutting-edge science, technology and innovation to help doctors, hospitals, pharmaceutical companies, researchers and patients make clear and confident decisions. We know our work matters and we strive to attain ethical excellence. Labcorp is a global leader of innovative and comprehensive laboratory services with more than 67,000 employees serving customers across the globe. Labcorp is diverse in thought, customs, people and cultures. We strive to work openly and collaboratively to share knowledge and accomplish Labcorp's mission.

Labcorp is committed to uncompromising integrity in all that we do and in how we relate to each other, our customers, our suppliers and vendors, and to the communities in which we operate and provide services. You should seek advice from your leadership, the Law or Compliance Department, or other appropriate personnel if you have questions about specific laws, rules or regulations.

Obeying the law is one of the foundations on which Labcorp's ethical principles are built. Each of us must respect and obey the governmental laws, rules and regulations of the cities, states and countries in which we operate.

This Code (1) promotes honest and ethical conduct, (2) addresses compliance with applicable governmental laws, rules, and regulations, (3) deters wrongdoing, and (4) fosters full, fair, accurate and timely disclosure of concerns or violations. Everyone at Labcorp has a duty to follow this Code and to

promote a culture of integrity and compliance.

What do I do if the Labcorp Code of Conduct and Ethics is stricter than the local law, practice or custom?

You must comply with the Labcorp Code of Conduct and Ethics.

What do I do if the local law has stricter requirements than the Labcorp Code of Conduct and Ethics?

You must comply with the law, local practice or custom.

If you have questions about possible conflicts, please ask your people leader, Law Department or Corporate Compliance Department.

Who Does the Code Apply To?

Unless explicitly excepted from a section, the Code applies to all Labcorp employees, officers, directors, agents, representatives, consultants, vendors and contractors. Each of us is required to read, understand and follow all relevant Labcorp policies and procedures and this Code. Compliance is everyone's responsibility.

Your Role

This Code, together with Labcorp's policies and procedures, provides information you need to perform your job ethically and in line with applicable laws and regulations.

Strive to do what is right

The Code cannot account for all scenarios; some may be unclear. You must use good judgment. If you observe or are asked to do something that makes you uncomfortable, seems improper, unlawful, or contrary to Labcorp policies or procedures, speak to the appropriate group, as discussed later in this Code.

Seek guidance and ask questions

If something does not seem right, ask your people leader, senior leadership, or the Law or Corporate Compliance Department to clarify.

Report any concerns or violations

If you have observed or are concerned about any possible violations of this Code or any laws or regulations, you have a duty to report this potential violation as discussed later in this Code.

Take inquiries and/or investigations seriously

Whether your daily responsibilities involve investigating potential violations or you are asked to participate in a particular inquiry or investigation, you must cooperate fully and to the best of your ability.

Do not retaliate against anyone reporting a concern or violation

Labcorp prohibits retaliation of any form (whether by a people leader, coworker or anyone else) against someone who has made a good faith report of a suspected violation of this Code, Labcorp policy or applicable law or regulation.

This Code is a guide for overall conduct in our global operations. It is not a substitute for the detailed guidance provided in Labcorp's Business Practices Manual, HIPAA Privacy and Security Manual, Human Resources policies, or other specific Company policies. You should consult with the Corporate Compliance Department and the Business Practices Manual for further guidance and discussion of many of the topics addressed in this Code. Look to any specific policies of Labcorp's various subsidiaries for guidance on specific topics and activities relevant to your responsibilities.

Those who violate this Code will be subject to disciplinary action as Labcorp deems appropriate, up to and including termination from Labcorp, and, potentially, civil liability and criminal prosecution.

If you are in a situation that you believe may violate or lead to a violation of this Code, you must report the situation according to the procedures discussed in this Code.

Special Responsibilities as a People Leader

As a people leader, you are highly visible and influential. Your behavior and actions matter to employees and impact their performance and engagement. You are expected to:

• Model ethical conduct including the standards in this Code
• Communicate the importance of this Code to employees and make sure they understand their responsibilities
• Create an environment where employees are comfortable asking questions and are supported when speaking up
• Respond promptly and properly to employees who raise concerns or seek advice
• Promptly report potential misconduct and escalate or investigate any reports made to you as appropriate
• Not retaliate or condone retaliation against anyone for sharing concerns in good faith or supporting an investigation
• Verify employees complete required training

Ethical Decision Making

For the Code to work most effectively, it is important to ask questions and voice concerns. Labcorp's "open door" practice gives you the freedom to approach any member of management with questions or concerns about ethics or compliance without fear of retaliation. We must all work to take prompt and consistent action against violations of this Code or applicable law. Because the Code cannot address every situation that will arise, it is important that we have a way to approach a new question or concern. Please consider the following:

• Use your judgment and common sense. If something makes you uncomfortable, seems unlawful, unethical, or improper, do not do it.
• Discuss the situation with your people leader or other appropriate personnel. This is the basic guidance for all situations. In many cases, your people leader will be more knowledgeable about the question and will appreciate being brought into the decision-makingprocess. If you are uncomfortable speaking with your people leader, please speak to other appropriate leadership.
• Seek help from corporate resources. In the event you do not feel comfortable approaching your people leader with your question, or you have done so but still have a concern, discuss it with your Corporate Compliance Department representative, the Law Department or your Human Resources representative.
• Always ask first, act later. If you are unsure of what to do or are uncomfortable in any situation, seek guidance before you act. Ask questions.

8

If you are unsure of "the right thing to do", before you act, ask these questions to guide you through the difficult situation:

Is the action or decision legal?

Does it comply with the Code of Conduct and Ethics?

Is it permitted under a Labcorp policy or

procedure?Does it align with Labcorp

values?

Would I feel comfortable explaining my decisions or actions to my colleagues, people leader, family or friends?

If your answer to any of these questions is no, please reconsider your actions and seek guidance to help make the right decision.

For More Information

Corporate Compliance Department - can

provide guidance on the Code, compliance policies, how we comply with the laws, regulations, and industry standards.

People Leaders and Senior Leadership - can offer advice on how the Code pertains to your particular role at Labcorp.

Law Department - can advise on how Labcorp can conduct its business in compliance with applicable laws and contractual obligations.

Human Resources - can explain and answer questions related to benefits, employment and workplace issues.

Courage

10 What Do I Do If I Know About or Suspect a Violation of the Code?

1. How Do I Report a Violation?
2. What Happens When I Report?

11 No Retaliation

What Do I Do If I Know About or Suspect a Violation of the Code?

If you suspect a violation of any laws, rules, regulations or this Code has occurred, you must proactively and promptly report it. When in doubt about the best course of action in a particular situation, you should report the concern. Failure to report a potential violation may be cause for discipline.

How Do I Report a Violation?

You may report a suspected violation or other concern via any of the following methods:

• Speak with your people leader
• Connect with Human Resources through HR Central
• Contact the Law Department, the Corporate Compliance Department or Corporate Internal Audit
• Speak with anyone else on the management team
• Call or report through the online portal for the Labcorp Action Line

Any people leader who receives a report of violation or potential violation of this Code or law must report it immediately to the Chief Legal Officer or the Corporate Compliance Department. Reports related to accounting, internal accounting controls,

or auditing matters will be forwarded to the Internal Audit Department.

Labcorp has established the Labcorp Action Line which can be used to ask questions or to report suspected or actual unlawful or unethical behavior or violations of law, rules, or regulations or of this Code or internal policies. You can reach the Labcorp Action Line 24 hours a day, seven days a week, in your preferred language by reporting online at Labcorp.ethicspoint.com, or via phone using one of the numbers listed on the online portal.

I want to report a concern, but I don't feel like I have all the information. What should I do?

You must report your good faith concern. You are not responsible to gather all the facts. If you know or suspect of an event that may be inconsistent with the Code, Labcorp policies or the law, you must speak up!

10

Reports may be made anonymously via the Labcorp Action Line, where permitted, but we encourage you to provide your name and a thorough description of your specific concern to facilitate the investigation. Whether or not you provide your name, all information will be kept confidential except to the extent required to inform individuals involved in the investigation of the complaint.

Employees are expected to cooperate in internal investigations of alleged misconduct. Any person involved in an investigation of possible misconduct in any capacity must not discuss or disclose any information to anyone outside of the investigation unless required by law or when seeking own legal advice.

People Leader Tip

People leaders have a responsibility to address employee concerns, including listening, discussing, escalating to the appropriate corporate resource and taking prompt action to resolve any such matter.

• Confirm the matter is reported or report it yourself
• Maintain confidentiality
• Do not conduct an investigation unless directed to by the Corporate Compliance, Law Department or Human Resources
• Connect with the appropriate resources if you need guidance
• Encourage cooperation with an investigator
• Avoid making representations about the outcome of the investigation

For More Information

Action Line Policy (BPM-10)

Whistleblowing Policy - France (BPM-10.1)