FONAR CORPORATION
ETHICS HOTLINE / WHISTLEBLOWER
PROGRAM
TO: All Employees of Fonar Corporation and Health Management Corporation
of America
FROM: The Audit Committee of Fonar Corporation
Introduction: Briefly stated, this is a program established
to provide any and all employees a confidential method to report
any incidents which they believe may be illegal or improper financial,
auditing or accounting conduct, any violation of the Company’s
Code of Conduct or other unethical behavior.
Purpose of Program: Under the Sarbanes-Oxley
Act, the audit committee of a company covered by the Act is required
to established procedures for (1) receiving and retaining information
about, and treating alleged incidents involving the company regarding
accounting, internal accounting controls or auditing matter and
(2) the confidential, anonymous submission of concerns by employees
about questionable accounting or auditing matters.
The Audit Committee: Our Audit Committee
consists only of independent directors who, among other things,
oversees auditing, accounting and financial matters and the maintenance
of honesty, integrity and appropriate controls and procedures
in order to assure that the financial statements of the Company
are accurate and properly prepared. The Audit Committee has the
final authority in selecting our auditors. The Audit Committee
presently consists of Charles O’Data, Robert Janoff and
Robert Djerejian.
Person to Contact: Charles O’Data,
the Chairman of Audit Committee is designated as the person to
contact. You can contact him by mail, fax or e-mail:
Your Right to Report: If you know or believe that any person
in the Company is doing anything which is illegal or improper
with respect to financial, accounting, auditing or following proper
procedures, you are encouraged to report the matter to the parties
designated below. The misconduct in question could range from
stealing, embezzlement, bribing or taking bribes, to improper
recording or reporting, or the improper withholding of information.
If you are in doubt as to whether or not to report an incident,
report it.
In addition to reporting matters of the type indicated
above, you have the right to report or communicate concerns, about
actual or potential violations of the Company’s Code of
Conduct, including unethical behavior and actual or suspected
fraud.
You also have the right to write obtain advice before
making decisions in the course of your work that appear to have
significant legal or ethical implications.
Confidentiality: Your name will be kept confidential
by the person you contact. You also have the right to make reports
anonymously. No retribution will be taken against an employee
making a report under this program.
Follow-Up: If you do not believe appropriate
remedial action has been taken, you have the option to report
directly to our external auditor, Marcum & Kliegman at 655
Third Avenue, 16th Floor, New York, New York 10017, Attention:
Steve Kriete or such other person Marcum & Kliegman may designate.
Non-exclusive: This program is designed to
give you a special protected way to discuss matters of concern
confidentially or anonymously. You may still discuss concerns
you have with supervisors, management, or the personnel department,
as you think is most appropriate.
M-11521
The undersigned employee acknowledges that he or she has received
Fonar Corporation’s Ethics Hotline/Whistleblower Program.
______________________________ ____________________
Name Date
Please sign and return to Personnel