It is our policy to conduct business affairs in accordance with the standards and rules of ethical business conduct and to abide by applicable laws, both in letter and spirit. In this, there is no room for compromise.
We understand the significance of the work we do and its impact on people's lives. Nothing is more important than conducting our business with honor, integrity and respect.
∂∂“ű's Ethics and Compliance program guides employees when conducting the business affairs of the organization, and stresses the tenet that "Compliance is Everyone‚Äôs Responsibility." We believe that each and every one of our employees is integral to maintaining the Company's reputation, and ∂∂“ű holds staff accountable to always take personal responsibility for choosing what is right.
We‚Äôre proud of the honorable reputation and exceptional culture we have built through the hard work and integrity of our employees. Our commitment to upholding this reputation and acting with the highest values and principles will never wane.
At ∂∂“ű, our Company‚Äôs success depends on a reputation for integrity and high ethical standards in everything we do. As such, even where the law is permissive, the Company chooses the course of the highest integrity.Őż
Our Ethics and Compliance Program provides methods by which we further enhance operations, safeguard against fraud and abuse and help ensure that our values are reflected in everything we do. Our Board of Directors (the Board) has adopted a Business Ethics and Code of Conduct Policy (the Policy) which is applicable to all directors, officers and employees of the Company, including the Principal Executive Officer, Principal Financial Officer and Principal Accounting Officer. It is reviewed and approved on an annual basis by our Board of Directors. While no policy can replace the thoughtful behavior of an ethical director, officer or employee, we believe the Policy will, among other things, focus our Board and management on areas of ethical risk, provide guidance for recognizing and responding to ethical issues, provide mechanisms to report unethical conduct and generally help foster a culture of honesty and accountability.
It is the policy of the Company to prevent the occurrence of unethical or unlawful behavior, to halt such behavior as soon as reasonably possible after its discovery, and to discipline directors, officers, or employees who violate the standards contained in the Policy. This includes any individuals who fail to report a known violation.
Violations of the Policy can be reported to any of the following:
- An employee‚Äôs People Leader;
- The Company‚Äôs Ethics and Compliance department;
- The Ethics and Compliance helpline or inbox.
In addition to our Business Ethics and Code of Conduct (PDF) policy, learn more about key features of our Ethics and Compliance program below.
All directors, officers, and employees of the Company are required to complete training modules covering our Business Ethics and Code of Conduct policy. In addition, our comprehensive training program also requires completion of annual courses covering fraud, waste, and abuse (FWA), privacy and confidentiality, and conflict of interest. Completion is monitored by our Ethics and Compliance Department, and reported to our Compliance Committee and the Board.
Key tenets of these courses, and the underlying policies, are reinforced through the deployment of signage, email campaigns, and periodic messaging from senior leadership of the Company.
The Company provides a toll-free Ethics & Compliance hotline which is available to employees, members, patients, business partners, and network providers to make anonymous, good faith reports of potential violations of our Business Ethics and Code of Conduct policy or potential bribery or corruption.
Additionally, we have a comprehensive program at the corporate and operating unit level for the prevention, detection and reporting of fraud, waste, and abuse. ∂∂“ű‚Äôs Special Investigations Unit (SIU) oversees the FWA program. The FWA Program is designed to prevent and reduce fraud, waste, and abuse among providers, members, patients, employees, and subcontractors. It may also help to prevent potential health risks to members and patients. A toll-free Fraud and Abuse Hotline is available to U.S. employees, members, patients, business partners, and network providers.
Both hotlines are administered by an independent third party vendor, are available 24/7, and provide for confidential, anonymous reporting. Any allegations received are thoroughly investigated by Company and/or external resources.
Our policy concerning pre-approval of related party transactions is incorporated into the provisions of the Policy. As part of the Policy, our directors, officers and employees are responsible for disclosing any transaction or relationship that reasonably could be expected to give rise to a conflict of interest to the Senior Vice President of Internal Audit, Compliance & Risk Management of the Company or the Board of Directors, in the case of an executive officer or director, who shall be responsible for determining whether such transaction or relationship constitutes a conflict of interest.
Most countries have established laws that prohibit private businesses from improperly influencing government employees. ∂∂“ű complies with all applicable anti-corruption and anti-bribery laws of the countries in which it conducts business. ∂∂“ű‚Äôs policies and anti-bribery laws, including the U.S. Foreign Corrupt Practices Act of 1977 (FCPA), strictly prohibit bribing government officials. Our commitment to complying with these laws and regulations is essential to maintaining ∂∂“ű‚Äôs reputation for integrity and fair business dealings. It is unlawful for employees, business partners, and anyone else acting on behalf of the Company to directly or indirectly offer anything of value to a foreign government official or their representative to:
- Obtain or retain business
- Influence business decisions
- Secure an unfair advantage
Whenever the recipient of a gift or entertainment is a government official or employee, there is a risk that such actions may be viewed as an inappropriate attempt to influence his or her decisions. To avoid even the perception of inappropriate conduct, gifts and entertainment given to or received from a government official or employee must be pre-approved by the Corporate Ethics & Compliance Department. Even if local law allows ‚Äúfacilitation‚ÄĚ payments to government officials to accelerate or guarantee routine actions, such as issuing licenses or permits, prior written approval from the Corporate Ethics & Compliance Department or Corporate Legal Department must be obtained before making any such payments. Furthermore, employees are prohibited from using intermediaries such as agents, advisers, or independent contractors to give or receive gifts or make payments to foreign government officials without the appropriate pre-approvals.
We have established a number of controls in order to promote and monitor compliance with our anti-bribery and anti-corruption policy, including:
- Use of a confidential, enterprise-wide Ethics and Compliance Hotline. Any reports are promptly investigated.
- Required annual training on our Business Ethics and Code of Conduct and the Foreign Corrupt Practices Act of 1977
- Required supervisory review of all expense reports, and routine, independent auditing of those reports
- Annual review and investigation of required annual Conflict of Interest filings
- Even if local law allows ‚Äúfacilitation‚ÄĚ payments to government officials to accelerate or guarantee routine actions, such as issuing licenses or permits, prior written approval from the Corporate Ethics & Compliance Department or Corporate Legal Department must be obtained before making any such payments.
∂∂“ű does not tolerate retaliation for reports of possible violations made in good faith, using any of the procedures described. Any employee who knowingly retaliates because of such a report, or who interferes with an investigation based on such a report, will be subject to disciplinary action up to and including termination of employment.