Healthy Neighbors Advocate Code of Conduct

Healthy Neighbors connects people with health research opportunities that may be relevant to them. Advocates help share approved information with their personal, professional, and community networks and may refer individuals who are interested in learning more.

This Advocate Code of Conduct explains the standards every Advocate must follow when representing Healthy Neighbors, sharing study information, communicating with potential participants, and submitting referrals.

By signing up as an Advocate, you agree to follow this Code of Conduct at all times.

As a Healthy Neighbors Advocate, your role is to:

• · Share Healthy Neighbors-approved study information.
• · Help identify people who may be interested in learning about a study.
• · Direct interested individuals to Healthy Neighbors or the study team.
• · Submit referrals only with the individual's permission.
• · Act respectfully, honestly, and professionally.

Your role is not to determine whether someone qualifies for a study, provide medical advice, interpret study requirements, or pressure anyone to participate.

Advocates may only use study materials, social media posts, text messages, flyers, scripts, links, and other content provided or approved by Healthy Neighbors.

You may not:

• · Create your own claims about a study.
• · Change eligibility criteria.
• · Add promises about treatment benefits.
• · Use misleading headlines or images.
• · Suggest that participation is guaranteed.
• · Suggest that compensation is guaranteed unless expressly approved.
• · Use Healthy Neighbors branding, logos, or study sponsor names in unapproved ways.

If you are unsure whether a message is allowed, ask Healthy Neighbors before sending or posting it.

Advocates are not permitted to provide medical advice.

You may not:

• · Tell someone they should or should not join a study.
• · Tell someone to start, stop, or change medication.
• · Interpret lab results, diagnoses, symptoms, or medical history.
• · Suggest that a study treatment will improve someone's health.
• · Tell someone a study is safe, effective, or appropriate for them.
• · Answer detailed medical questions about a study.

If someone asks a medical question, you should say:

“I'm not able to provide medical advice, but I can connect you with the study team so they can answer your questions.”

Advocates may explain that someone may be eligible or may qualify, but only the study team can determine actual eligibility.

You may not say:

• · “You qualify.”
• · “You will be accepted.”
• · “You will be enrolled.”
• · “You will receive the treatment.”
• · “You will be paid.”
• · “This will help your condition.”
• · “There is no risk.”

Approved language includes:

• · “You may be eligible.”
• · “The study team will confirm whether you qualify.”
• · “Participation is voluntary.”
• · “Compensation may be available if you qualify and participate, depending on the study.”

Participation in any research study is voluntary. Advocates must respect each person's choice.

You may not:

• · Pressure, harass, or repeatedly contact someone who is not interested.
• · Use fear, guilt, urgency, or emotional manipulation.
• · Target people who cannot understand the information being shared.
• · Take advantage of vulnerable individuals.
• · Misrepresent yourself as a doctor, nurse, researcher, study employee, or medical professional unless you are specifically authorized and licensed to do so.
• · Promise special treatment or faster access.

If someone says they are not interested, you must stop contacting them about that study.

All Advocate communications must be accurate, clear, and honest.

You agree not to:

• · Make false, exaggerated, or misleading statements.
• · Hide important information.
• · Misrepresent the study purpose.
• · Misrepresent the time commitment, location, payment, risks, or requirements.
• · Falsify referral information.
• · Submit fake, duplicate, or unauthorized referrals.
• · Claim that Healthy Neighbors, a study site, or a sponsor has endorsed statements they have not approved.

If you share study information on social media, by text, by email, or in public posts, you must clearly disclose that you may receive a referral fee or other compensation from Healthy Neighbors.

The Federal Trade Commission states that social media disclosures should be included with the endorsement message itself and that people should disclose material connections to a brand or company when sharing endorsements or promotional content. (ftc.gov)

Approved disclosure examples include:

• · “I may receive a referral fee from Healthy Neighbors.”
• · “Paid referral opportunity.”
• · “I’m a Healthy Neighbors Advocate and may be compensated for referrals.”
• · “#ad” or “#paidreferral” where appropriate.

Disclosures must be easy to see, easy to understand, and not hidden in a long list of hashtags or at the end of a hard-to-read post.

You may not submit another person's name, phone number, email address, health information, or other personal information unless they have given you permission.

Before submitting a referral, you should ask:

“Do I have your permission to share your name and contact information with Healthy Neighbors or the study team so they can contact you with more information?”

If the person says no, do not submit their information. You may provide them with your referral link so they can choose whether to complete the form themselves.

Advocates may learn personal or health-related information about people in their network. You must protect that information.

You agree to:

• · Keep personal and health information private.
• · Collect only the minimum information needed for a referral.
• · Use Healthy Neighbors-approved systems to submit referrals.
• · Not share someone's health information publicly.
• · Not post names, diagnoses, symptoms, photos, or stories without written permission.
• · Not discuss referrals with unauthorized people.
• · Follow the Healthy Neighbors Privacy Rules.

Advocates must treat all individuals fairly and respectfully.

You may not discriminate based on:

• · Race
• · Color
• · Religion
• · National origin
• · Sex
• · Gender identity or expression
• · Sexual orientation
• · Age
• · Disability
• · Veteran status
• · Marital status
• · Health condition
• · Insurance status
• · Income level
• · Language
• · Any other protected status under applicable law

Advocates may share approved study information through appropriate channels, including personal conversations, text messages, emails, community outreach, and social media, subject to Healthy Neighbors rules.

You may not:

• · Spam people.
• · Buy contact lists.
• · Scrape phone numbers or emails.
• · Use robocalls or automated texting without authorization.
• · Post in groups that prohibit recruitment or promotional content.
• · Contact people in ways that violate platform rules.
• · Enter restricted healthcare facilities, senior communities, clinics, or private events without permission.
• · Misrepresent yourself to gain access to people or locations.

When posting online, Advocates must:

• · Use only approved content.
• · Include required compensation disclosures.
• · Avoid medical claims.
• · Avoid discussing a person's private health information.
• · Avoid arguing with commenters.
• · Remove or report inappropriate comments when possible.
• · Direct interested individuals to the approved link or study team.

Do not publicly confirm that a person has a condition or is interested in a study. If someone comments publicly, reply generally:

“Thanks for your interest. Please message me directly or use the link to learn more.”

Advocates may be eligible to receive referral fees or other compensation according to Healthy Neighbors' payment policies.

You understand that:

• · Payment is not guaranteed unless all payment conditions are met.
• · Payment may depend on referral quality, eligibility, completed screening, enrollment, or other study-specific requirements.
• · False, duplicate, unauthorized, or fraudulent referrals will not be paid.
• · Healthy Neighbors may withhold payment if this Code of Conduct is violated.
• · You are responsible for any taxes related to Advocate compensation.

Advocates may be allowed to participate in a study if they personally qualify.

If you qualify and participate, you may be eligible to earn both:

• · The applicable referral fee, if permitted by Healthy Neighbors policy; and
• · Any applicable study participation compensation.

Participation is always voluntary and subject to study eligibility requirements, informed consent, and Healthy Neighbors' payment policies.

You must disclose any relationship or circumstance that could create a conflict of interest, including if you are:

• · A healthcare provider referring your own patients.
• · An employee or contractor of a study site, sponsor, healthcare facility, senior living community, or medical practice.
• · In a position of authority over potential participants.
• · Referring people who may feel pressured because of your relationship with them.

Healthy Neighbors may restrict or prohibit certain referrals to protect participants and comply with applicable law and study rules.

You must promptly report concerns to Healthy Neighbors, including:

• · Suspected privacy incidents.
• · Unauthorized disclosure of personal or health information.
• · Misleading statements by another Advocate.
• · Pressure or coercion of potential participants.
• · Fraudulent referrals.
• · Complaints from participants.
• · Requests to stop contact.

Reports can be made to: Healthy Neighbors Compliance Contact — compliance@healthy-neighbors.com

Violating this Code of Conduct may result in:

• · Warning or retraining.
• · Suspension of Advocate account.
• · Termination from the Advocate program.
• · Loss or withholding of referral payments.
• · Removal of referrals.
• · Reporting to appropriate authorities if required by law.
• · Legal action, where appropriate.

By clicking “I Agree,” signing electronically, or continuing with Advocate registration, I acknowledge and agree that:

• · I have read and understand the Healthy Neighbors Advocate Code of Conduct.
• · I will follow all Healthy Neighbors policies and approved outreach instructions.
• · I will not provide medical advice.
• · I will not guarantee study eligibility, enrollment, results, treatment, or payment.
• · I will obtain permission before submitting any referral.
• · I will protect personal and health information.
• · I understand that failure to follow this Code may result in suspension, termination, non-payment, and/or other consequences.