Human Resources
Policy/Procedure Title:
Non-Retaliation
Approved By:
Date of Issue:
April 1, 2009
Revision Dates:
Policy Number:
HR125
Last
Review
Date:
Don Nickleson, CEO
Purpose:

To state a commitment to zero tolerance for retaliation of any kind against
Comprehensive Pharmacy Services (CPS) employees who may, in the course of their
employment, report incidents of unethical or unlawful behavior such as workplace
harassment or business operations fraud or abuse.
Scope:
 All Comprehensive Pharmacy Services employees.
Definitions, for purposes of this policy:
 Abuse – Incidents or practices that are inconsistent with accepted medical, business, or
fiscal practices. Abuse may directly or indirectly result in improper payment, payment for
services that fail to meet professionally recognized standards of care, or services that are
medically unnecessary. Abuse involves payments for items or services when there is no
legal entitlement to that payment and the provider has not knowingly and intentionally
misrepresented facts to obtain the payment.
 Fraud – The intentional deception or misrepresentation that an individual knows to be false
or does not believe to be true and makes, knowing that the deception could result in some
unauthorized benefit to himself / herself or some other person or entity.
 Harassment – Harassment is unwelcome behavior that is personally offensive, impairs
morale, and interferes with work effectiveness. Examples of such behavior includes, but is
not limited to: offensive, abusive, or degrading comments or other verbal behavior, slurs,
epithets, threats, derogatory comments, unwelcome jokes and teasing as well as written or
pictorial materials.
 Retaliation -- Any form of sanction or adverse treatment against a person because that
person has asserted, or has assisted another person to assert, a good faith complaint with
CPS or any state or federal agency, or because that person has testified or participated in
any manner in an authorized investigation, proceeding, or hearing related to a complaint of
unethical or unlawful behavior such as workplace harassment or business operations fraud
or abuse.
 Whistleblower – A person who informs on another or makes public disclosure of corruption
or wrongdoing.
Policy:
HR125 Non-Retaliation
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I.
CPS shall not tolerate retaliation in any form against any employee who in good faith
reports known or suspected violations of law or CPS policy, or participates in any
manner in an authorized investigation, proceeding or hearing related to a report, or
opposes unlawful harassment or discrimination of others.
II.
CPS maintains an “open door policy” at all levels of management to encourage
employees to report problems or concerns:
A.
CPS encourages its employees to report to their manager, Human Resources
Department, Compliance Office, or any Leadership Team member, known or
suspected violations of law, regulation, CPS policy, or Code of Conduct.
III.
CPS shall treat all reports and conduct all investigations as discreetly as possible, to
further employee protection against retaliation.
Procedures:
A.
Report known or suspected acts of retaliation to the CPS supervising Manager,
Human Resources Department, Compliance Office, or any Leadership Team
member.
B.
The CPS Human Resources Department and/or Compliance Office shall
promptly and thoroughly investigate all reports of retaliation.
C.
Any CPS employee who is responsible for acts of retaliation shall be subject to
corrective action, up to and including termination.
These policies do not create a contract of employment for any length of time, nor does it change the at-will nature of
employment. Some of the policies described may require further interpretations. The Company reserves the right to
add, modify, or terminate its employee policies, practices and procedures and/or benefits at any time. This on-line
policy supersedes all prior policies, including (without limitation, any hard-copy version of this policy previously
distributed) and all prior practices and procedures on subjects covered in this policy. Because our on-line policies are
updated from time to time, employees should review the on-line policies to be informed of the current policies in
effect.
HR125 Non-Retaliation
Final approval DN/04012009
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