The purpose of this Code of Conduct is to provide guidance to the employees of Company, and assist in carrying out daily activities within appropriate ethical and legal standards.
These ethical and legal standards apply to our relationships with members, providers, employer groups, vendors, consultants, regulatory agencies, joint venture partners as well as to one another.
Although this Code of Conduct can neither cover every situation in the daily conduct of our many varied activities nor substitute for common sense, individual judgment or personal integrity, it is the duty of each employee to adhere, without exception, to the principles set forth in this Code of Conduct.
Company is striving to maintain its reputation for excellence by enforcing the highest systemwide standards of ethics, efficiency and conduct. It is an objective of the Compliance Plan to establish guidelines and procedures reasonably capable of reducing the prospect of unlawful conduct.
While all employees of Company are obligated to follow this Code of Conduct, we expect our leaders to set the example. Our leaders must ensure that all employees have sufficient information to comply with laws, regulations and policies; as well as the resources to resolve ethical dilemmas. Our leaders must help to create a culture within Company that promotes the highest standards of ethics and compliance.
The Board of Directors made a commitment to compliance when they passed a resolution calling for the creation and implementation of a Compliance Program. An excerpt from this resolution made on August 24, 1998, follows.
It is further resolved that the corporate compliance program contain at a minimum a Code of
Conduct, including compliance standards and procedures reasonably capable of reducing the prospect of unlawful conduct; supervision and oversight by the highest level of staff with overall responsibility to oversee compliance with the established standards and procedures; audit tools and procedures to ensure due care is used to prevent delegation of substantial discretionary authority to individuals who have been identified as having a propensity to engage in unlawful activities; develop an education program to ensure that the standards and procedures are communicated effectively to all the corporation’s employees and other agents; a reporting system that demonstrates the corporation has taken reasonable steps to achieve compliance with its standards and procedures; a discovery mechanism to insure that the standards and procedures are consistently enforced; and an action plan to implement after an offense has been detected that takes into consideration all reasonable steps to respond to the detected offense.
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The complete Resolution can be found in the Code of Conduct folder of the Proof of Plan files
(POP files) located in the Compliance Department.
We have developed a Compliance Plan that provides written guidance to performing the tasks underlined above. For a copy of the Compliance Plan refer to the Compliance Program shelf in the Document Management System. A copy is also located in the POP files located in the
Compliance Department.
This Code of Conduct should embrace the core values of Company that are to:
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Communicate openly and honestly and settle differences respectfully and through appropriate avenues
Show compassion and caring for our members
Use common sense in solving problems on behalf of our members
Show consideration for fellow employees, management and colleagues
Cooperate in accommodating requests that are in the best interest of our members and our organization even though it may not always be in an individual employee’s best interest
This Code of Conduct should also be perceived as a means of accomplishing our mission, which is to provide competitive insurance products that maximize value to shareholders, purchasers and members.
Through this Code of Conduct, we can assure that Members’ Rights are adhered to and actions of Company employees and our participating providers protect these Members’ Rights. Our members’ rights are listed below.
Members have the right to:
 Be treated with respect and recognition of their dignity and right to privacy
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Reasonable access to health care
Participate with practitioners in decision-making regarding their health care
A candid discussion of appropriate or medically necessary treatment options for their condition, regardless of cost or benefit coverage
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To receive information about Company, its services, its practitioners and providers, and
Members’ Rights and Responsibilities
To voice complaints or appeals about Company or the care provided
Make recommendations regarding the Company Members’ Rights and Responsibilities policies
The Compliance Plan contains the following:
 A description of the supervision and oversight of the Compliance effort
The Board of Directors has designated the Director of Compliance as the Compliance
Officer. A condensed list of this position’s job responsibilities is found in the Compliance
Plan. A Compliance Committee provides high-level oversight of the compliance efforts.
This Committee will meet quarterly and their meeting minutes presented to the Board of
Directors.
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 specific areas of risk and vulnerability within our organization.
All approved policies and procedures are to be kept in our organization’s document management system, Document Management System. Policies and procedures are to be reviewed on an annual basis and revised accordingly.
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Compliance standards, policies and procedures
Policies and procedures are developed in conjunction with the Compliance Plan and for
Training and education plans
The Compliance Plan calls for both general and specialized training. General training is provided to all employees. New employees are educated through the new employee orientation process. General training addresses the components of this Code of Conduct as well as the key elements of the Compliance Plan. All employees are required to sign an acknowledgment and understanding of the Code of Conduct form .
Specialized training is performed as new regulations are passed and policies and procedures have been developed or changed for those employees affected by the changes.
 Avenues for employees to report potential offenses
Employees have a personal and ethical obligation to report any suspected violations to their supervisor. However, we realize there are circumstances that would make such a disclosure uncomfortable or inappropriate. Therefore other avenues have been developed
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 to report compliance concerns or suspected violations. You may report suspected misconduct or a compliance violation by calling the Compliance Line at 123-4567 or via email at complianceline@company.org
. These avenues are also communicated to employees via posters, badges and the
Reporting Suspected Misconduct and Compliance Violations policy and procedure.
Risk assessment and the audit program
Risk assessments will be conducted on an annual basis to determine possible risk areas.
An audit program has been developed to provide guidance for key staff when conducting internal audits.
Investigation and action plan
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Internal investigations into suspected misconduct and possible compliance violations will be conducted according to the Internal Compliance Investigations policy and procedure.
If an internal investigation uncovers a compliance violation, a corrective action plan will be enacted. This plan will include making prompt restitution of any error, notifying the appropriate governmental agency, when appropriate, instituting whatever employee disciplinary action is necessary, and implementing changes to prevent a similar violation from recurring in the future.
Strategies to avoid relationships with individuals engaged in unlawful activities
We are prohibited from hiring, contracting with or engaging the services of any individual or company that has committed illegal activities. A high level of personal and professional integrity is expected from all employees, providers and vendors.
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We are committed to an environment which compliance with rules, regulations (state and federal), and sound business practices is woven into the corporate culture. We accept the responsibility to aggressively self-govern and monitor adherence to the requirements of law and to this Code of Conduct.
We must never sacrifice ethical and compliant behavior in the pursuit of business and financial objectives.
With this commitment in mind, if you encounter a situation or are considering a course of action, which potentially may be in violation of any legal or ethical issue, you are encouraged to contact your supervisor, the Compliance Officer or the Compliance Line for guidance. There will be no retribution for asking questions, raising concerns or reporting possible violations in good faith.
The mission, values and visions of Company should be pursued with fairness, honesty and integrity.
Company expects each employee to abide by this Code of Conduct and participate willingly in the Compliance Program efforts.
Failure to abide by this Code of Conduct will result in disciplinary action. The precise disciplinary action will depend on the nature, severity and frequency of the violation and may result in any of the following disciplinary actions per the Clinic Disciplinary Policy and the
Disciplinary Policy Addendum for Company Employees which are located on the Document
Management System under the Administrative Policies folder.
This Code of Conduct and the written Compliance Plan do not address the myriad of human resources related policies with which you are obligated to follow. You are encouraged to read the
Company Association’s policies and procedures that are found on Company’s web site,
CompanyWEB .
All existing and new employees will be required to read and sign off on this Code of Conduct .
Please contact your immediate supervisor or the Compliance Officer if you have any questions about this Code of Conduct or your obligations as an employee of Company and Company
Clinic.
Nothing in this Code of Conduct is intended to nor shall be construed as providing any additional employment or contract rights to employees or other persons.
While Company will generally attempt to communicate changes concurrent with or prior to the implementation of such changes,
Company reserves the right to modify, amend or alter this Code of Conduct without notice to any person or employee.
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