Code of Professional Conduct

This Code of Professional Conduct governs the professional standards, ethical obligations, and conduct expectations that apply to all consulting engagements conducted by Viturtal Consulting, operated by Midwest Business Consulting LLC. It reflects our commitment to the clients we serve, the integrity of the work we perform, and the professional standards appropriate to a firm advising on operational and financial decisions that affect dental practices, dental service organizations, and the private equity sponsors who invest in them.

This Code applies to all consulting engagements. It does not govern advisory board roles, speaking engagements, academic affiliations, or other non-consulting activities of Dr. Hendrik Lai or Midwest Business Consulting LLC.

1. Client Confidentiality

1.1 Confidentiality Obligation

All information shared by clients in the course of a consulting engagement — including financial data, operational performance data, strategic plans, personnel information, payor contract details, transaction information, and any other non-public information — is treated as strictly confidential. Viturtal Consulting does not disclose, share, publish, or otherwise communicate client-specific information to any third party without the express written consent of the client.

This obligation applies during the engagement and continues indefinitely after the engagement concludes. There is no expiration on the confidentiality obligations Viturtal Consulting assumes with respect to client information.

1.2 Anonymized Case Studies and Published Outcomes

Viturtal Consulting publishes anonymized case studies and impact statements that describe engagement outcomes. These publications are prepared under the following standards:

• All identifying information is removed — including client name, specific geographic locations, named personnel, and any other detail that could reasonably identify the client organization.
• Published financial figures — including total opportunity identified, EBITDA projections, and workstream-level outcomes — reflect actual engagement findings. Viturtal Consulting does not fabricate, inflate, or selectively present outcome data in published case studies or impact statements.
• Engagement characteristics that could identify a client — such as specific location counts, exact revenue figures, or unique operational configurations — are generalized or described in ranges rather than precise figures where identification risk exists.
• Viturtal Consulting does not publish case study content derived from a client engagement without first ensuring that the content meets these anonymization standards. Where a client requests that no case study be published from their engagement, that request is honored without exception.

1.3 Internal Use of Client Information

Client information accessed during an engagement is used exclusively for the purpose of performing the engagement. It is not used to inform work for other clients, to develop proprietary benchmarking products, or for any purpose other than the direct delivery of the engagement scope.

2. Conflicts of Interest

2.1 Definition

A conflict of interest exists when Viturtal Consulting's obligations to a client are or may be compromised by a competing interest — including a financial interest, a relationship with another party, or an obligation arising from another engagement or advisory role.

2.2 Disclosure Obligation

Viturtal Consulting will disclose to a prospective client any known conflict of interest before accepting an engagement. If a conflict of interest arises during an engagement, Viturtal Consulting will disclose it to the client promptly and before taking any action that could be affected by the conflict.

Disclosure is made directly to the senior client contact responsible for the engagement. It is made in writing where the nature of the conflict warrants a documented record.

2.3 Conflict Management

Where a conflict of interest is disclosed, Viturtal Consulting and the client will determine together whether the conflict can be managed in a way that preserves the integrity of the engagement — through appropriate information barriers, scope limitations, or other agreed measures — or whether the engagement should not proceed or should be concluded.

Viturtal Consulting will not allow a conflict of interest to influence the substance of advice, the content of deliverables, or the recommendations made to a client. Where a conflict cannot be adequately managed, Viturtal Consulting will decline or withdraw from the engagement.

2.4 Competitive Engagements

Viturtal Consulting does not simultaneously serve directly competing clients within the same geographic market and service category without the informed consent of both clients. Where a potential competitive conflict is identified, it is disclosed to both parties and the engagement proceeds only with their explicit agreement.

3. Accurate Representation

3.1 Credentials and Qualifications

Viturtal Consulting represents the credentials, qualifications, academic affiliations, and professional designations of Dr. Hendrik Lai accurately and completely. Credentials listed on viturtal.com and in engagement materials reflect actual academic degrees, professional certifications, and organizational affiliations that are current or accurately described as historical where appropriate.

Viturtal Consulting does not claim credentials that have not been earned, affiliations that do not exist, or recognitions that have not been received. Where credentials are honorary, conditional, or time-limited, they are described accurately.

3.2 Engagement Outcomes and Case Studies

Viturtal Consulting represents engagement outcomes — including financial improvements, identified opportunities, and operational changes — accurately and in the context in which they were achieved. Specifically:

• Published outcome figures represent actual findings from completed engagements — not projections, estimates, or illustrative scenarios presented as actual results.
• Outcome figures are presented in the metric in which they were identified — opportunity identified, EBITDA improvement, revenue recovered — and are not restated in a more favorable metric without clear disclosure of the change in measurement basis.
• Outcome figures are not aggregated or combined across engagements in a way that is misleading about the scale or nature of any individual engagement.
• Viturtal Consulting does not publish, cite, or represent success rates, client counts, implementation counts, or other aggregate performance statistics that are not supported by verifiable engagement records.

3.3 Scope of Expertise

Viturtal Consulting represents its areas of expertise accurately. Viturtal Consulting's primary expertise is in dental practice operations, DSO operational consulting, and private equity value creation in dental — and engagements are accepted within those areas of demonstrated competence. Where an engagement requires expertise outside Viturtal Consulting's core competency, that limitation is disclosed to the client.

4. Professional Standards

4.1 Independence of Judgment

Viturtal Consulting's recommendations, analysis, and advice are based on the evidence gathered during the engagement and the professional judgment of Dr. Hendrik Lai. Recommendations are not influenced by the desire to expand engagement scope, extend the duration of an engagement, or maintain a consulting relationship beyond its useful term.

Where the evidence supports a recommendation that is not in Viturtal Consulting's commercial interest — including recommending against an engagement, recommending a shorter or narrower scope than proposed, or recommending against a course of action the client prefers — Viturtal Consulting makes that recommendation.

4.2 Objectivity

Viturtal Consulting presents findings — including findings that reflect unfavorably on the client organization, its management, or its historical decisions — honestly and directly. Findings are not softened, omitted, or reframed to avoid uncomfortable conclusions. Clients retain Viturtal Consulting for the quality of its analysis and the honesty of its recommendations — not for validation of decisions already made.

4.3 Client Capability Building

Viturtal Consulting's engagements are designed to build the client organization's internal capability rather than create ongoing dependency on external consulting support. Operating systems, dashboards, accountability structures, and analytical frameworks are designed to function without external facilitation after the engagement concludes. Viturtal Consulting does not structure engagements to maximize consulting revenue at the expense of client capability development.

4.4 Respect for Clinical Integrity

Viturtal Consulting recognizes that dental consulting engagements occur in a clinical environment where patient care is the primary obligation of the professionals we advise. Operational and financial recommendations are made with explicit awareness that clinical quality and patient safety are not subordinate to financial performance objectives. Viturtal Consulting will not recommend operational changes that compromise clinical standards, patient safety, or regulatory compliance in pursuit of financial improvement.

5. Compliance with Laws and Regulations

Viturtal Consulting conducts all consulting engagements in compliance with applicable laws and regulations, including those governing healthcare operations, data privacy, and professional conduct. Where an engagement involves regulated activities — including healthcare billing practices, HIPAA-governed data, or state dental board requirements — Viturtal Consulting advises clients to engage appropriate legal and compliance counsel and does not provide legal, regulatory, or compliance advice beyond the operational scope of the engagement.

6. Reporting Concerns

Clients, prospective clients, or other parties who believe Viturtal Consulting has failed to meet the standards set out in this Code of Professional Conduct are invited to raise those concerns directly with Dr. Hendrik Lai at hendrik@viturtal.com. Concerns will be reviewed promptly and responded to in writing within 10 business days.

7. Amendments

Viturtal Consulting reserves the right to amend this Code of Professional Conduct at any time. Amendments are effective upon publication at viturtal.com/code-of-professional-conduct. Clients with active engagements at the time of amendment will be notified of material changes.