CODE OF ETHICS AND PROFESSIONAL CONDUCT

Size: px
Start display at page:

Download "CODE OF ETHICS AND PROFESSIONAL CONDUCT"

Transcription

1 CODE OF ETHICS AND PROFESSIONAL CONDUCT Mission To provide adults, caregivers and families with programs and services promoting an enhanced quality of life. Family Alliance, Inc. has a clearly stated charitable mission, approved by the governing body, in pursuit of the public good. The mission is responsive to the constituency and communities to be served by Family Alliance. Code of Ethics Given its mission, Family Alliance, Inc. has adopted a code of ethics to guide its board members, committee members and staff in their conduct when acting on behalf of Family Alliance. The Code contains broad principles reflecting the types of behavior Family Alliance expects towards constituents, employees, peers and the public. The Code is intended to provide a framework for ethical decision-making, as no Code can provide specific guidance for all situations. This policy is not intended as a stand-alone policy. It does not embody the totality of Family Alliance s ethical standards, nor does it answer every ethical question or issue that might arise. Rather, it is one element of a broader effort to create and maintain a quality organization that gives ethical conduct the highest priority. This Code shall be reviewed annually. Compliance, Monitoring and Reporting Family Alliance s management is responsible for communicating this Code of Ethics and Professional Conduct to all employees and volunteers and for ensuring its contents are understood and followed. Violations of any of the foregoing provisions may expose Family Alliance, Inc. and the individuals involved to lawsuits and possible criminal action. Staff members who violate this policy are subject to appropriate disciplinary action, up to and including termination. Any alleged violations of this policy will be reviewed by the agency s legal counsel and other appropriate staff members, and they will determine the appropriate action to take. Each employee and officer is responsible for promptly reporting to the agency and circumstances that such person believes in good faith may constitute a violation of this policy in accordance with the Duty to Report Policy. I. AGENCY COMMITMENTS As an employee, you represent Family Alliance, Inc. You have a responsibility to treat the people we serve with respect, courtesy and efficiency.

2 A. Upon hiring, the following commitment is made to each employee: 1. You will be treated with respect and dignity. 2. The environment will provide the potential for maximum growth. 3. The environment will be conducive to open communication. 4. Challenges will be provided. 5. All employees will be treated equally and fairly. 6. A commitment will be made to work with each individual s strengths. B. Each employee is expected: 1. To work as a team. 2. To not place blame. 3. To remind each of us of our mission and vision. 4. To volunteer rather than be asked. 5. To accept change. 6. To continuously challenge themselves to improve. 7. To serve as a reporter of abuse or neglect and cooperate in any investigation by OIG II. PROFESSIONAL CONDUCT A. Act at all times in accordance with the highest ethical standards and in the best interest of Family Alliance, its constituents and reputation exercising care, good faith and due diligence in organizational affairs. B. Strive for personal growth in the field, excellence and innovation, and demonstrate professional respect and responsiveness to constituents and others. C. Support the mission and values of the agency. D. Work cooperatively with all co-workers. E. Maintain loyalty to Family Alliance, Inc. F. Refrain from developing personal relationships with individuals seeking service at the agency and abide by the Ethical Boundary Policy G. Improve the public understanding of the role of adult care. H. Refrain from using an employment position for personal gain. I. Be responsible for proper care of the environment and equipment. J. Be responsible for honest personnel time records. K. Ensure appropriate use of county, Federal, private grantors, and agency property and funds. L. Adhere to the agency organizational chart, follow proper chain of command, and comply with expectations as defined in job descriptions. M. Contribute to an organizational culture that respects the diverse, individual contributions of staff and leadership. N. Respect the confidentiality of sensitive information about Family Alliance, its clients, constituents, board and employees. Family Alliance respects and protects the confidentiality and privacy rights of individual clients, grantees, employees, donors, volunteers and others in the agency consistent with applicable law. O. Comply with applicable federal, state and local laws, regulations and fiduciary responsibilities and immediately report suspected dishonest or fraudulent behavior. The Board of Directors and staff are educated on and comply with all federal, state and local

3 laws, regulations and fiduciary responsibilities, seeking professional legal and accounting advice when needed to support compliance. P. Adhere to document retention policy Q. For the Board of Directors, provide credible and effective oversight to the organization s work. The governing body members have the requisite skills and experience to carry out their duties. The Board of Directors regularly assesses Family Alliance s mission and the effectiveness of the agency and its leadership in achieving it. R. Abide by the governing documents and policies of Family Alliance, including the Conflict of Interest and Corporate Compliance policies. Family Alliance staff and Board of Directors are educated about what constitutes conflict of interest and prevent or manage any actual, potential or perceived conflicts through disclosure, abstention or other means. S. Be accountable for adhering to this Code of Ethics. III. Clinical Ethics Family Alliance, Inc. has an obligation to its clients, third party payers and the state and federal government to exercise diligence, care and integrity when submitting claims for payment. Family Alliance, Inc. is committed to maintaining the accuracy of every claim it processes and submits. Any false, inaccurate, or questionable claims should be reported immediately to the employee s supervisor or the Compliance Officer. False billing is a serious offense. Medicaid rules prohibit knowingly and willfully making or causing to be made any false statement or representation of the material fact in an application for benefits or payment. It is also unlawful to conceal or fail to disclose the occurrence of an event affecting the right to payment with the intent to secure payment that is not due. With respect to the submission of claims, a claim must: A. Be accurate and submitted in a timely manner, B. Be only for items or services that are 1. medically necessary, 2. fall within the coverage guidelines contained in applicable laws, rules and regulations, and 3. are documented in the clients clinical record In this regard, prior to submitting a claim for payment, it is necessary to verify that all documentation for services reflected on the claim, such as physician orders and prior approvals, are available in a proper and timely manner. Claims may only be submitted when appropriate documentation supports the claim and only when such documentation is maintained and available for audit and review. Documentation which serves as the basis for a claim must be appropriately organized in legible form so that such documentation may be audited and reviewed. Diagnosis and procedures reported on reimbursement claims must be based on the clinical record and other documentation. Documentation necessary for accurate code assignment must be made available to all employees with coding responsibility. It is strictly prohibited to:

4 Bill for items or services not provided Bill for services with the belief that the bill may be denied Duplicate billing Upcode Fail to monitor medical necessity on an on-going basis Falsify information on the claim form and/or accompanying documentation Alter medical records Manipulate the client s diagnosis in an attempt to receive improper payment Fail to maintain medical necessity documentation Falsify use of location of service codes Improperly solicit a client with activities and high-pressure marketing of noncovered or unnecessary services IV. FINANCIAL ETHICS A. Financial Record-Keeping It is the policy of Family Alliance, Inc. to fully and fairly disclose the financial condition of the agency in compliance with the applicable accounting principles laws, rules and regulations and to make full, fair, accurate, timely and understandable disclosure in our periodic reports. Honest and accurate recording and reporting of information is critical to our ability to make responsible business decisions. Family Alliance s accounting records are relied upon to produce reports for the agency s management, rating agencies, creditors, governmental agencies and others. Therefore, financial statements and the books and records on which they are based must accurately reflect all corporate transactions and conform to all legal and accounting requirements. The system of internal control is designed to provide this information. All employees have a responsibility to ensure that Family Alliance s accounting records do not contain any false or intentionally misleading entries. Information on which our accounting records are based is the responsibility of all employees. Family Alliance, Inc. does not permit intentional misclassification or transactions as to accounts, departments or accounting periods. In particular, Family Alliance, Inc. requires that: All agency accounting records, as well as reports produced from those records, are kept and presented in accordance with the laws of each applicable jurisdiction All records fairly and accurately reflect the transactions or occurrences to which they relate All records fairly and accurately reflect in reasonable detail the agency s assets, liabilities, revenues and expenses The agency s accounting records do not contain any intentionally false or misleading entries No transactions are misclassified as to accounts, departments or accounting periods All transactions are supported by accurate documentation in reasonable detail and recorded in the proper account and in the proper accounting period

5 All agency accounting financial reports be prepared in accordance with generally accepted accounting principles The agency s system of internal accounting controls, including compensation controls, to be followed at all times B. Improper Payments No payment or transfer of the agency s funds or assets shall be made that is not authorized, properly accounted for and clearly identified in the agency s books. Payment or transfer of the agency s funds and assets are to be used only as specified in the supporting documents. No employee or officer may authorize any payment or use any funds or assets for a bribe, kickback, or similar payment that is directly or indirectly for the benefit of any individual (including any government official, agent, or employee anywhere in the world,) company or agency in the United States or any foreign country, and which is designed to secure favorable treatment for the agency. Under federal legislation, it is a felony to make payments of this kind to foreign government officials. C. Political Contributions It is Family Alliance s policy not to contribute any agency funds or assets to any political party, committee, organization or candidate for any office (federal, state or local,) in the United States or any foreign country. Employees may, on their own time, support individual candidates or political committees, all subject to applicable laws, and may make voluntary contributions to such candidates or committees, including any agency-related political action committee. D. Acceptance of Payments Employees and officers may not seek or accept either directly or indirectly, any payments, fees, services, or other gratuities (irrespective of size or amount) outside the normal course of the employee s business duties from any other person, company or organization that does or seeks to do business with Family Alliance. Gifts of cash or cash equivalents of any amount are strictly prohibited. The receipt of common courtesies, sales promotion items of nominal value, occasional meals, and reasonable entertainment appropriate to a business relationship and associated with business discussions are permissible. E. Business Entertainment All solicitations or dealings with suppliers, customers, or others doing or seeking to do business with Family Alliance shall be conducted solely on a basis that reflects both the agency s best interests and its high ethical standards. The agency does permit the providing of common courtesies, entertainment, and occasional meals for potential or actual suppliers, customers, or others involved with the agency s business, in a manner appropriate to the agency s relationship and associated with business discussions. Expenses in this connection must be reasonable, customary and properly authorized.

6 F. Confidentiality All employees and officers are responsible for safeguarding and keeping confidential any information that Family Alliance considers to be of a confidential or sensitive nature. Such information includes, but is not limited to, financial records and reports, marketing and strategic planning information, employee-related documents, unpublished manuscripts as well as information relating to potential mergers and acquisitions, and other materials that Family Alliance would not want disclosed to a competitor or any unauthorized recipient, or that might be harmful to the agency if disclosed, whether or not such information is marked confidential. Confidential information also includes information concerning possible transactions with other companies or information about the agency s clients, suppliers or joint venture partners, which Family Alliance is under an obligation to maintain as confidential. Employees and officers may not use confidential information for their own personal benefit or the benefit of persons or entities outside the agency, and must exercise caution and discretion with respect to any appropriate temporary removal of confidential or sensitive information from Family Alliance s premises, and should safeguard the information from unintended disclosure or loss. G. Fair Dealing Each employee and officer should endeavor to deal fairly with Family Alliance s suppliers, competitors and employees. No one should take unfair advantage of another through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair-dealing practice. Information about the agency s competitors must be used in an ethical manner and in compliance with the law. Under no circumstance should information be obtained through theft, illegal entry, blackmail or electronic eavesdropping, or through employees misrepresenting their affiliation with Family Alliance or their identity. Any proprietary or non-public information about the agency s competitors should not be used if it is suspected that such information has been obtained improperly.

7 V. MARKETING ETHICS A. The Family Alliance, Inc. Development Department will not solicit from the following foundations or corporations who: 1. Require a position on abortion or right-to-life issues 2. Require a political position 3. Want Family Alliance, Inc. to run on their model of service 4. Are on the McHenry United Way Do Not Solicit list 5. Do not fund unsolicited proposals, as listed in the Donor s Forum database 6. Do not fund seniors, adults, healthcare or some combination of Family Alliance s programs/services/activities, (i.e. food service, animals, music, art, horticultural, etc.) B. Family Alliance, Inc. will professionally and accurately represent its services, programs, staffing, funding, and community support in all printed marketing materials and verbal presentations. C. Family Alliance, Inc. strives to prepare its marketing materials without discrimination to age, gender, sexual preference, race, ethnicity, religious affiliation, etc. D. Family Alliance, Inc. requires a client/family signed release prior to photographic or written (testimonial) publication. E. Family Alliance, Inc. solicits funding from all McHenry County religious organizations, regardless of affiliation. F. Family Alliance, Inc. will not utilize any materials, printed or premiums, which could be deemed as sexually explicit or containing sexual innuendo, containing references to alcohol or drug use, or those that prescribe to any religious or political affiliation. G. Family Alliance, Inc. will use positive, person-centered language when describing its programs, services, clients, etc.

EADS-NA Code of Ethics

EADS-NA Code of Ethics Page: 1 of 7 EADS-NA Code of Ethics Introduction The Company demands high ethical standards of conduct from its directors, employees, and agents and will conduct its business with honesty, integrity, and

More information

Helix Energy Solutions Group, Inc. Code of Business Conduct and Ethics

Helix Energy Solutions Group, Inc. Code of Business Conduct and Ethics Helix Energy Solutions Group, Inc. Code of Business Conduct and Ethics Introduction This Code of Business Conduct and Ethics ( Code ) covers a wide range of business practices and procedures. It does not

More information

Minerals Technologies Inc. Summary of Policies on Business Conduct

Minerals Technologies Inc. Summary of Policies on Business Conduct Minerals Technologies Inc. Summary of Policies on Business Conduct Lawful and Ethical Behavior is Required at All Times This Summary of Policies on Business Conduct (this "Summary") provides an overview

More information

RENREN INC. CODE OF BUSINESS CONDUCT AND ETHICS. This Code is designed to deter wrongdoing and to promote:

RENREN INC. CODE OF BUSINESS CONDUCT AND ETHICS. This Code is designed to deter wrongdoing and to promote: RENREN INC. CODE OF BUSINESS CONDUCT AND ETHICS I. PURPOSE This Code of Business Conduct and Ethics (the Code ) contains general guidelines for conducting the business of Renren Inc., a Cayman Islands

More information

Asterias Biotherapeutics, Inc. Code Of Business Conduct And Ethics. March 10, 2013

Asterias Biotherapeutics, Inc. Code Of Business Conduct And Ethics. March 10, 2013 Asterias Biotherapeutics, Inc. Code Of Business Conduct And Ethics March 10, 2013 This Code of Business Conduct and Ethics (the "Code") sets forth legal and ethical standards of conduct for directors,

More information

WESTERN ASSET MORTGAGE CAPITAL CORPORATION CODE OF CONDUCT

WESTERN ASSET MORTGAGE CAPITAL CORPORATION CODE OF CONDUCT WESTERN ASSET MORTGAGE CAPITAL CORPORATION CODE OF CONDUCT I. Introduction This Code of Conduct (the "Code") sets out basic principles to guide the day-today business activities of directors, officers

More information

Standards of. Conduct. Important Phone Number for Reporting Violations

Standards of. Conduct. Important Phone Number for Reporting Violations Standards of Conduct It is the policy of Security Health Plan that all its business be conducted honestly, ethically, and with integrity. Security Health Plan s relationships with members, hospitals, clinics,

More information

code of Business Conduct and ethics

code of Business Conduct and ethics code of Business Conduct and ethics Introduction This document provides information about our Code of Business Conduct and Ethics. All directors, officers and employees are individually and collectively

More information

Ryanair Holdings PLC Code of Business Conduct & Ethics 2012

Ryanair Holdings PLC Code of Business Conduct & Ethics 2012 Ryanair Holdings PLC Code of Business Conduct & Ethics 2012 1 TABLE OF CONTENTS 1. INTRODUCTION 3 2. WORK ENVIRONMENT 3 2.1 Discrimination & Harassment 3 2.2 Privacy of Personal Information 3 2.3 Internet

More information

GENERAL COMPLIANCE POLICY & PROCEDURE

GENERAL COMPLIANCE POLICY & PROCEDURE GENERAL COMPLIANCE POLICY & PROCEDURE Department: All Departments General Policy: 001 Subject: Code of Ethics Product: All Product Lines HCPCS: N/A Original Date: August 28, 1998 Change Order: C010332

More information

1. Compliance with Laws, Rules and Regulations

1. Compliance with Laws, Rules and Regulations CODE OF BUSINESS CONDUCT - EXAMPLE INTRODUCTION This Code of Business Conduct covers a wide range of business practices and procedures. It does not cover every issue that may arise, but it sets out basic

More information

Sanchez Energy Corporation. Code of Business Conduct and Ethics

Sanchez Energy Corporation. Code of Business Conduct and Ethics Sanchez Energy Corporation Code of Business Conduct and Ethics Introduction The Board of Directors (the Board ) of Sanchez Energy Corporation (the Company ) has adopted this Code of Business Conduct and

More information

SM ENERGY COMPANY CODE OF BUSINESS CONDUCT AND CONFLICT OF INTEREST POLICY

SM ENERGY COMPANY CODE OF BUSINESS CONDUCT AND CONFLICT OF INTEREST POLICY SM ENERGY COMPANY CODE OF BUSINESS CONDUCT AND CONFLICT OF INTEREST POLICY We at SM Energy Company are committed to compliance with applicable laws, rules and regulations and to conducting our business

More information

DLI CODE OF BUSINESS CONDUCT & ETHICS

DLI CODE OF BUSINESS CONDUCT & ETHICS DLI CODE OF BUSINESS CONDUCT & ETHICS All DLI employees, regardless of where they are located, must conduct their affairs with uncompromising honesty and integrity. Business ethics are no different from

More information

Destiny Media Technology s Code of Conduct

Destiny Media Technology s Code of Conduct Destiny Media Technology s Code of Conduct INTRODUCTION Destiny Media Technology s ( Destiny ) reputation depends on the conduct of its employees, officers and directors who have an obligation to Destiny

More information

WHAT IS A COMPLIANCE PLAN

WHAT IS A COMPLIANCE PLAN Code of Conduct WHAT IS A COMPLIANCE PLAN AND CODE OF CONDUCT? The Compliance Plan and Code of Conduct are formal statements of EPIC s standards and rules of ethical business conduct. We need a Compliance

More information

Message from the Co-Chairmen and Chief Executive Officers

Message from the Co-Chairmen and Chief Executive Officers Message from the Co-Chairmen and Chief Executive Officers As each of us works to meet individual and Company-wide business goals here at Torchmark, we must all ensure that the work we perform and the business

More information

CORNERSTONE THERAPEUTICS INC. SECOND AMENDED AND RESTATED CODE OF BUSINESS CONDUCT AND ETHICS

CORNERSTONE THERAPEUTICS INC. SECOND AMENDED AND RESTATED CODE OF BUSINESS CONDUCT AND ETHICS CORNERSTONE THERAPEUTICS INC. SECOND AMENDED AND RESTATED CODE OF BUSINESS CONDUCT AND ETHICS This Second Amended and Restated Code of Business Conduct and Ethics (the Code ) sets forth legal and ethical

More information

VisionQuest Code of Conduct

VisionQuest Code of Conduct VisionQuest Code of Conduct Code of Conduct The Code of Conduct guides all employees and contractors by establishing minimum mandatory standards of conduct for individual decision-making while performing

More information

CODE OF BUSINESS CONDUCT AND ETHICS

CODE OF BUSINESS CONDUCT AND ETHICS Effective: 1 st April 2015 Table of Contents 1. PURPOSE... 3 2. SCOPE... 3 3. OWNERSHIP... 3 4. DEFINITIONS... 3 5. CONFLICTS OF INTEREST... 3 6. CORPORATE OPPORTUNITIES... 4 7. CONFIDENTIALITY AND PRIVACY...

More information

Ur-Energy Inc. Code of Business Conduct and Ethics

Ur-Energy Inc. Code of Business Conduct and Ethics Ur-Energy Inc. Code of Business Conduct and Ethics As Amended Effective February 5, 2014 2957409.2 TABLE OF CONTENTS INTRODUCTION... 3 CONFLICTS OF INTEREST... 3 GIFTS, INVITATIONS AND ENTERTAINMENT GUIDELINES...

More information

MOTORCAR PARTS OF AMERICA, INC. CODE OF BUSINESS CONDUCT AND ETHICS ADOPTED EFFECTIVE JANUARY 15, 2015

MOTORCAR PARTS OF AMERICA, INC. CODE OF BUSINESS CONDUCT AND ETHICS ADOPTED EFFECTIVE JANUARY 15, 2015 MOTORCAR PARTS OF AMERICA, INC. CODE OF BUSINESS CONDUCT AND ETHICS ADOPTED EFFECTIVE JANUARY 15, 2015 The Board of Directors of Motorcar Parts of America, Inc. ( MPA ) has adopted the following Code of

More information

a. employees Company; or

a. employees Company; or Code of Busines ss Conduct and Ethics 1. Introduction a. This Code of Business Conduct and Ethics (the Code ) applies to all directors, officers, employees and third parties employed or directly engaged

More information

Bottomline s Code of Business Conduct and Ethics

Bottomline s Code of Business Conduct and Ethics Bottomline s Code of Business Conduct and Ethics Bottomline Technologies (the Company) Code of Business Conduct and Ethics is the compass by which directors, officers, employees and contractors (each,

More information

PHILIPPINE LONG DISTANCE TELEPHONE COMPANY CODE OF BUSINESS CONDUCT AND ETHICS

PHILIPPINE LONG DISTANCE TELEPHONE COMPANY CODE OF BUSINESS CONDUCT AND ETHICS PHILIPPINE LONG DISTANCE TELEPHONE COMPANY CODE OF BUSINESS CONDUCT AND ETHICS Philippine Long Distance Telephone Company ( PLDT or the Company ) is dedicated to doing business in accordance with the highest

More information

PHILIP MORRIS INTERNATIONAL INC.

PHILIP MORRIS INTERNATIONAL INC. PHILIP MORRIS INTERNATIONAL INC. Code of Business Conduct and Ethics for Directors 1. Introduction This Code of Business Conduct and Ethics for Directors ( Code ) has been adopted by Philip Morris International

More information

NewLead Holdings Ltd. Code of Ethics

NewLead Holdings Ltd. Code of Ethics NewLead Holdings Ltd. Code of Ethics The Board of Directors of NewLead Holdings Ltd., (the Company ) has adopted this Code of Ethics (the Code ) for all of the Company s employees, directors, officers

More information

CORPORATE GOVERNANCE

CORPORATE GOVERNANCE CORPORATE GOVERNANCE Ethics are vital to Brown Strauss, Inc. (Brown Strauss) and each of its and employees. Brown Strauss is committed to the highest ethical standards and to conducting its business with

More information

Copyright 2012, General Dynamics Information Technology. All Rights Reserved.

Copyright 2012, General Dynamics Information Technology. All Rights Reserved. Introduction Over the years, General Dynamics Information Technology has experienced significant growth in its IT services business serving government and commercial customers worldwide. As a valued supplier

More information

Letter from the Chief Executive Officer and Chairman and the Group Medical Director

Letter from the Chief Executive Officer and Chairman and the Group Medical Director Letter from the Chief Executive Officer and Chairman and the Group Medical Director Every day, millions of people put their trust in International SOS to help them wherever they live or travel. We remain

More information

Group Policy 1. INTRODUCTION 2. BUSINESS INTEGRITY. 2.1. Honesty, Integrity & Fairness

Group Policy 1. INTRODUCTION 2. BUSINESS INTEGRITY. 2.1. Honesty, Integrity & Fairness Corporate Code of Conduct and Ethics Policy Approver: CEO Valid from: 26-11-13 1. INTRODUCTION CRI recognizes its responsibilities as a global services provider, and is committed to being a responsible

More information

NRG ENERGY, INC. SUPPLIER CODE OF CONDUCT. Revision 1, Released June 10, 2014

NRG ENERGY, INC. SUPPLIER CODE OF CONDUCT. Revision 1, Released June 10, 2014 NRG ENERGY, INC. SUPPLIER CODE OF CONDUCT Revision 1, Released June 10, 2014 Ethics toll-free Helpline 888.263.0463-1 Table of Contents INTRODUCTION and MESSAGE FROM CEO 3 NRG STRIVE VALUES 4 ETHICS HELPLINE

More information

California Mutual Insurance Company Code of Business Conduct and Ethics

California Mutual Insurance Company Code of Business Conduct and Ethics California Mutual Insurance Company Code of Business Conduct and Ethics This Code of Business Conduct and Ethics (the Code ) applies to all officers, employees, and directors of California Mutual Insurance

More information

COMPLIANCE PROGRAM AND COMPLIANCE CODE OF CONDUCT

COMPLIANCE PROGRAM AND COMPLIANCE CODE OF CONDUCT COMPLIANCE PROGRAM AND COMPLIANCE CODE OF CONDUCT I. COMPLIANCE PROGRAM IN GENERAL A. MISSION. B. PURPOSE. It is the mission of My Choice Family Care ( MCFC ) to respect the dignity and personal autonomy

More information

PC CONNECTION, INC. CODE OF BUSINESS CONDUCT AND ETHICS

PC CONNECTION, INC. CODE OF BUSINESS CONDUCT AND ETHICS I. Purpose. PC CONNECTION, INC. CODE OF BUSINESS CONDUCT AND ETHICS Applicable to All Subsidiaries To establish uniform standards of conduct under which each of the PC Connection, Inc. family of companies

More information

UNIVERSAL INSURANCE HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS. Revised as of March 3, 2014

UNIVERSAL INSURANCE HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS. Revised as of March 3, 2014 I. Statement of Policy UNIVERSAL INSURANCE HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS Revised as of March 3, 2014 Universal Insurance Holdings, Inc. ( UIH ) and its subsidiaries (collectively,

More information

UNITED WAY OF GREATER GREENSBORO, INC. CODE OF ETHICS

UNITED WAY OF GREATER GREENSBORO, INC. CODE OF ETHICS UNITED WAY OF GREATER GREENSBORO, INC. CODE OF ETHICS The Board of Directors of the United Way of Greater Greensboro, Inc. (the Organization ) has adopted the following Code of Ethics, which applies to

More information

Evergreen Solar, Inc. Code of Business Conduct and Ethics

Evergreen Solar, Inc. Code of Business Conduct and Ethics Evergreen Solar, Inc. Code of Business Conduct and Ethics A MESSAGE FROM THE BOARD At Evergreen Solar, Inc. (the Company or Evergreen Solar ), we believe that conducting business ethically is critical

More information

Administrative Policy and Procedure Manual. Code of Conduct Effective Date: 1/2005 Scope: Organizationwide Page 1 of 9

Administrative Policy and Procedure Manual. Code of Conduct Effective Date: 1/2005 Scope: Organizationwide Page 1 of 9 Scope: Organizationwide Page 1 of 9 I. Purpose The purpose of this policy is to provide direction to staff members to assist in carrying out daily activities within appropriate ethical and legal standards.

More information

CIVEO CORPORATION CORPORATE CODE OF BUSINESS CONDUCT AND ETHICS. Effective as of May 5, 2014

CIVEO CORPORATION CORPORATE CODE OF BUSINESS CONDUCT AND ETHICS. Effective as of May 5, 2014 CIVEO CORPORATION CORPORATE CODE OF BUSINESS CONDUCT AND ETHICS Effective as of May 5, 2014 Purpose This Corporate Code of Business Conduct and Ethics (this Code ) contains the policies that relate to

More information

CODE OF BUSINESS CONDUCT AND ETHICS

CODE OF BUSINESS CONDUCT AND ETHICS CODE OF BUSINESS CONDUCT AND ETHICS Introduction This (the Code ) applies to Oceaneering International, Inc. and its subsidiaries and other affiliated companies (together referred to as our Company, us

More information

GROUP POLICY MANUAL CODE OF CONDUCT AND ETHICS POLICY

GROUP POLICY MANUAL CODE OF CONDUCT AND ETHICS POLICY POLICY NO: 8 (Group) Issued: November 2007 Revision No: 1 GROUP POLICY MANUAL CODE OF CONDUCT AND ETHICS POLICY Original Issued: 22 August, 2003 Effective: November 2007 Date Reviewed: February 2007 By:

More information

HIGHMARK INC. THIRD PARTY CODE OF BUSINESS CONDUCT

HIGHMARK INC. THIRD PARTY CODE OF BUSINESS CONDUCT HIGHMARK INC. THIRD PARTY CODE OF BUSINESS CONDUCT HIGHMARK.COM TABLE OF CONTENTS Overview...1 Highmark Inc. s Obligations to Third Parties...1 Highmark Inc. s Expectations for Third Parties...3 Highmark

More information

Code of Conduct. martinhealth.org

Code of Conduct. martinhealth.org Code of Conduct martinhealth.org CODE OF CONDUCT Table of Contents A Note from the CEO 1 Mission Statement 2 Vision Statement 2 ICARE Values 2 The Corporate Compliance Program 3 Introduction 3 Corporate

More information

FS-5-101 Rev 1.2 Page 1 of 11

FS-5-101 Rev 1.2 Page 1 of 11 Page 1 of 11 First Solar, Inc. (Adopted as of October 3, 2006; revised July 29, 2015) Introduction This of First Solar, Inc. and its subsidiaries (the Company ) summarizes the values, principles and business

More information

VETERANS RESOURCE CENTERS OF AMERICA CORPORATE COMPLIANCE PLAN

VETERANS RESOURCE CENTERS OF AMERICA CORPORATE COMPLIANCE PLAN VETERANS RESOURCE CENTERS OF AMERICA CORPORATE COMPLIANCE PLAN COMPLIANCE STATEMENT Veterans Resource Centers of America (VRCOA) is committed to provide the highest quality behavioral health prevention

More information

QUMU CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS POLICY INTRODUCTION

QUMU CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS POLICY INTRODUCTION QUMU CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS POLICY INTRODUCTION Our Commitment The Code Applicability of Code We are committed to conducting our business lawfully and ethically. We promote a culture

More information

QIAGEN N.V. CORPORATE CODE OF CONDUCT AND ETHICS

QIAGEN N.V. CORPORATE CODE OF CONDUCT AND ETHICS QIAGEN N.V. CORPORATE CODE OF CONDUCT AND ETHICS This Corporate Code of Conduct and Ethics, referred to as the Code, is intended to provide our associates, as defined below, with a clear understanding

More information

CODE OF ETHICS POLICY

CODE OF ETHICS POLICY CODE OF ETHICS POLICY The YMCA's reputation is dependent upon the good judgment, ethical standards and personal integrity of every individual in the YMCA. As the YMCA continues to grow, it is of paramount

More information

Code of Business Conduct

Code of Business Conduct 4 8 F A C T O R I N G Code of Business Conduct Dear Colleague: Since its foundation 48 Factoring has been committed to maintaining the highest ethical standards. Our core values exemplify our drive for

More information

GLAUKOS CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS

GLAUKOS CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS GLAUKOS CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS This Code of Business Conduct and Ethics (the Code ) contains general guidelines for conducting the business of Glaukos Corporation (the Company

More information

Hyatt Hotels Corporation. Code of Business Conduct and Ethics

Hyatt Hotels Corporation. Code of Business Conduct and Ethics INTRODUCTION This (this Code ) is designed to reaffirm and promote Hyatt Hotels Corporation s compliance with laws and ethical standards applicable in all jurisdictions in which Hyatt Hotels Corporation

More information

WARREN RESOURCES, INC CODE OF BUSINESS CONDUCT AND ETHICS

WARREN RESOURCES, INC CODE OF BUSINESS CONDUCT AND ETHICS WARREN RESOURCES, INC CODE OF BUSINESS CONDUCT AND ETHICS This Code of Business Conduct and Ethics (this "Code") applies to Warren Resources, Inc. and its consolidated subsidiaries (collectively, the "Company").

More information

CODE OF CONDUCT. Providers, Suppliers and Contractors

CODE OF CONDUCT. Providers, Suppliers and Contractors CODE OF CONDUCT Providers, Suppliers and Contractors Table of Contents Code of Conduct... Honesty and integrity... Quality and Service... Responsibilities of Providers, Suppliers and Contractors... Compliance

More information

MOLINA HEALTHCARE, INC. CODE OF BUSINESS CONDUCT AND ETHICS

MOLINA HEALTHCARE, INC. CODE OF BUSINESS CONDUCT AND ETHICS MOLINA HEALTHCARE, INC. CODE OF BUSINESS CONDUCT AND ETHICS The Board of Directors of Molina Healthcare, Inc. has adopted this Code with respect to the business conduct and practices governing the affairs

More information

CODE OF ETHICS AND BUSINESS CONDUCT

CODE OF ETHICS AND BUSINESS CONDUCT CODE OF ETHICS AND BUSINESS CONDUCT Date of Issue: 22 January 2015 Version number: 2 LUXFER HOLDINGS PLC Code of Ethics and Business Conduct Luxfer Holdings PLC is committed to conducting its business

More information

ORVANA MINERALS CORP. CODE OF BUSINESS CONDUCT AND ETHICS ADOPTED BY THE BOARD OF DIRECTORS. October 2, 2013

ORVANA MINERALS CORP. CODE OF BUSINESS CONDUCT AND ETHICS ADOPTED BY THE BOARD OF DIRECTORS. October 2, 2013 ORVANA MINERALS CORP CODE OF BUSINESS CONDUCT AND ETHICS ADOPTED BY THE BOARD OF DIRECTORS October 2, 2013 -2- CODE OF BUSINESS CONDUCT AND ETHICS Orvana Minerals Corp is a publicly-traded Canadian company

More information

Steve Todare A MESSAGE FROM OUR PRESIDENT

Steve Todare A MESSAGE FROM OUR PRESIDENT CODE OF CONDUCT A MESSAGE FROM OUR PRESIDENT S&M Moving Systems has a history and a commitment of service to our clients, to our employees & to our communities. Our mission is to provide a quality product

More information

Albany Medical Center Code of Conduct Approved by the AMC Board of Directors 07/05/06

Albany Medical Center Code of Conduct Approved by the AMC Board of Directors 07/05/06 Albany Medical Center Code of Conduct Approved by the AMC Board of Directors 07/05/06 Rev. 11/5/03, 7/5/06 TABLE OF CONTENTS Introductory Letter from Mr. Barba 1 Quality and Excellence 2 Safety Credentials

More information

CODE OF CONDUCT. Care Excellence: providing quality, compassionate, respectful and clinically appropriate care to patients.

CODE OF CONDUCT. Care Excellence: providing quality, compassionate, respectful and clinically appropriate care to patients. CODE OF CONDUCT Individually and as an organization, the Clinic and its officers, employees and independent contractors (collectively referred to as Clinic Staff ) share in a commitment to legal, ethical

More information

Code of Business Conduct

Code of Business Conduct Code of Business Conduct Our Employees We treat each other with fairness, respect, and dignity, offering equal opportunities to all individuals. Intimidation, harassment, or discrimination based on race,

More information

VANDA PHARMACEUTICALS INC.

VANDA PHARMACEUTICALS INC. VANDA PHARMACEUTICALS INC. CODE OF ETHICS AND BUSINESS CONDUCT (As of May 22, 2014) 1. POLICY STATEMENT The reputation and integrity of Vanda Pharmaceuticals Inc. (the Company ) are valuable assets that

More information

CODE OF CONDUCT as adopted by the Board of Directors on 20 February 2015

CODE OF CONDUCT as adopted by the Board of Directors on 20 February 2015 GOLDFIELDS MONEY LIMITED ACN 087 651 849 CODE OF CONDUCT as adopted by the Board of Directors on 20 February 2015 1. Purpose This Code of Conduct (Code) clearly states the standards of responsibility and

More information

BERKSHIRE HATHAWAY INC. CODE OF BUSINESS CONDUCT AND ETHICS

BERKSHIRE HATHAWAY INC. CODE OF BUSINESS CONDUCT AND ETHICS BERKSHIRE HATHAWAY INC. CODE OF BUSINESS CONDUCT AND ETHICS A. Scope. This Code of Business Conduct and Ethics applies to all Berkshire Hathaway directors, officers and employees, as well as to directors,

More information

Code of Conduct of JTH Holding, Inc. Liberty Tax Service

Code of Conduct of JTH Holding, Inc. Liberty Tax Service Code of Conduct of JTH Holding, Inc. Liberty Tax Service Comments from John Hewitt: At Liberty Tax Service, being a principles-led company is more than a list of ideals it is a part of our mission. Our

More information

ELEMENT FINANCIAL CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS

ELEMENT FINANCIAL CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS APPENDIX I ELEMENT FINANCIAL CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS As of December 14, 2011 1. Introduction This Code of Business Conduct and Ethics ( Code ) has been adopted by our Board of Directors

More information

ELECTRO RENT CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS CANADA

ELECTRO RENT CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS CANADA ELECTRO RENT CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS CANADA Dear Colleague: Since its founding in 1965, Electro Rent has always prided itself on maintaining and delivering quality products and

More information

Pioneer Power Solutions, Inc. Code of Business Conduct and Ethics

Pioneer Power Solutions, Inc. Code of Business Conduct and Ethics A. INTRODUCTION Pioneer Power Solutions, Inc. Code of Business Conduct and Ethics The purpose of this Code of Business Conduct and Ethics (this Code ) is to describe standards of conduct and business expected

More information

COLLINS FOODS LIMITED (the COMPANY) CODE OF CONDUCT

COLLINS FOODS LIMITED (the COMPANY) CODE OF CONDUCT COLLINS FOODS LIMITED (the COMPANY) CODE OF CONDUCT 1. Introduction The Company is committed to maintaining ethical standards in the conduct of its business activities. The Company's reputation as an ethical

More information

CUBIC ENERGY, INC. Code of Business Conduct and Ethics

CUBIC ENERGY, INC. Code of Business Conduct and Ethics CUBIC ENERGY, INC. Code of Business Conduct and Ethics Introduction Our Company s reputation for honesty and integrity is the sum of the personal reputations of our directors, officers and employees. To

More information

C&J ENERGY SERVICES LTD. CORPORATE CODE OF BUSINESS CONDUCT AND ETHICS (Adopted as of March 24, 2015)

C&J ENERGY SERVICES LTD. CORPORATE CODE OF BUSINESS CONDUCT AND ETHICS (Adopted as of March 24, 2015) CORPORATE CODE OF BUSINESS CONDUCT AND ETHICS (Adopted as of March 24, 2015) The Board of Directors (the Board ) of C&J Energy Services Ltd. (the Company ) has adopted this Corporate Code of Business Conduct

More information

NVR HUMAN RESOURCES POLICIES AND PROCEDURES

NVR HUMAN RESOURCES POLICIES AND PROCEDURES DISTRIBUTION: ALL PAGE: 1 of 9 1. SCOPE AND PURPOSE NVR, Inc. and its subsidiaries ( NVR or the Company ) are committed to the highest level of ethical behavior. NVR s business success depends upon the

More information

I. Compliance with Applicable Governmental Laws, Rules, Regulations, and Agreements

I. Compliance with Applicable Governmental Laws, Rules, Regulations, and Agreements Updated: 2.18.2007 Check Point Software Technologies Ltd. CODE OF ETHICS AND BUSINESS CONDUCT Purpose The Board of Directors ( Board ) of Check Point Software Technologies Ltd. ( Check Point ) has adopted

More information

PEREGRINE SEMICONDUCTOR CORPORATION CODE OF ETHICS AND BUSINESS CONDUCT. Amended as of and Effective April 22, 2015

PEREGRINE SEMICONDUCTOR CORPORATION CODE OF ETHICS AND BUSINESS CONDUCT. Amended as of and Effective April 22, 2015 PEREGRINE SEMICONDUCTOR CORPORATION CODE OF ETHICS AND BUSINESS CONDUCT Amended as of and Effective April 22, 2015 1. POLICY STATEMENT The reputation and integrity of Peregrine Semiconductor Corporation

More information

POSTMEDIA NETWORK CANADA CORP. (the Company )

POSTMEDIA NETWORK CANADA CORP. (the Company ) POSTMEDIA NETWORK CANADA CORP. (the Company ) CODE OF BUSINESS CONDUCT AND ETHICS INTRODUCTION This Code of Business Conduct and Ethics ( Code ) covers a wide range of business practices and procedures.

More information

Johnson Electric Group Code of Ethics and Business Conduct

Johnson Electric Group Code of Ethics and Business Conduct Johnson Electric Group Code of Ethics and Business Conduct Chairman s Message Johnson Electric strives to conduct its business with honesty and integrity, both within the Group and in dealing with business

More information

LAMAR ADVERTISING COMPANY CODE OF BUSINESS CONDUCT AND ETHICS

LAMAR ADVERTISING COMPANY CODE OF BUSINESS CONDUCT AND ETHICS LAMAR ADVERTISING COMPANY CODE OF BUSINESS CONDUCT AND ETHICS This Code of Business Conduct and Ethics (the Code ) sets forth legal and ethical standards of conduct for directors, officers and employees

More information

OMNI TECHNICAL SOLUTIONS. Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy

OMNI TECHNICAL SOLUTIONS. Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy OMNI TECHNICAL SOLUTIONS Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy Updated: September 2015 Table of Contents 1. Introduction... 2 2. Business Ethics... 3 2.1 Compliance...

More information

ORGANIZATIONAL DOCUMENTS. a. An ownership or investment interest in any entity with which NAM has a transaction or arrangement,

ORGANIZATIONAL DOCUMENTS. a. An ownership or investment interest in any entity with which NAM has a transaction or arrangement, ORGANIZATIONAL DOCUMENTS Certificate of Incorporation By-Laws Conflict of Interest Policy Article I - Purpose The purpose of the conflict of interest policy is to protect the interest of the Nonprofit

More information

Complying with the U.S. Foreign Corrupt Practices Act

Complying with the U.S. Foreign Corrupt Practices Act Complying with the U.S. Foreign Corrupt Practices Act 1. About This Manual This Manual describes the Foreign Corrupt Practices Act ( FCPA ), 15 U.S.C. 78m, 78dd, 78ff (collectively, FCPA ), anti-corruption

More information

Business Ethics and Code of Conduct. Executives and employees. Global Connections Pcl.

Business Ethics and Code of Conduct. Executives and employees. Global Connections Pcl. Business Ethics and Code of Conduct. Executives and employees. Global Connections Pcl. Update on December 2013 Page 2 of 12 Contents. Subject Page Introduction 4 The aim of the company 4 Treatment of Stakeholders

More information

Standards of Ethical Conduct

Standards of Ethical Conduct Standards of Ethical Conduct Purpose Pursuit of the University of California mission of teaching, research and public service requires a shared commitment to the core values of the University as well as

More information

Code of Conduct ACS-DOBFAR

Code of Conduct ACS-DOBFAR Code of Conduct ACS-DOBFAR Board of Directors of 23/10/2012 The success of one company is based on values of transparency, credibility and loyalty, principles that represent the heritage of a company:

More information

Memo. Professional Accounts, LLC. Corporate Compliance Program

Memo. Professional Accounts, LLC. Corporate Compliance Program Professional Accounts, LLC Memo To: All Employees and Vendors From: Lee Frans, Executive Director Date: April 2, 2012 Re: Corporate Compliance Program Our mission as an organization has been to deliver

More information

KAM Specialties, Inc. (KAM) Code of Ethics

KAM Specialties, Inc. (KAM) Code of Ethics KAM Specialties, Inc. (KAM) Code of Ethics Date Approved : 11/15/2010 Introduction KAM s executive management is responsible for setting standards of business ethics and overseeing compliance with these

More information

CORPORATE GOVERNANCE. Code of Business Conduct & Ethics

CORPORATE GOVERNANCE. Code of Business Conduct & Ethics CORPORATE GOVERNANCE Ethics are vital to AZCON and its employees. AZCON is committed to the highest ethical standards and to conducting its business with the highest level of integrity. These values must

More information

CODE OF ETHICS AND BUSINESS CONDUCT

CODE OF ETHICS AND BUSINESS CONDUCT CODE OF ETHICS AND BUSINESS CONDUCT This Code of Ethics and Business Conduct ( Code ) has been approved by the Amalgamated Holdings Limited ( AHL ) Board of Directors for use within the AHL controlled

More information

company policy number 0001 LEGAL AND ETHICAL CONDUCT

company policy number 0001 LEGAL AND ETHICAL CONDUCT company policy number 0001 LEGAL AND ETHICAL CONDUCT eff. date replaces page 28 Mar. 2011 14 Feb. 2006 1 of 10 PURPOSE CPI has adopted this Code of Legal and Ethical Conduct ( Code ) to promote: honest

More information

Code of Ethics and Conduct

Code of Ethics and Conduct Introduction: Vale s mission is to transform natural resources into prosperity and sustainable development, aiming to be the number one global natural resources company in creating long term value, through

More information

OK INTERNATIONAL, INC. CODE OF BUSINESS CONDUCT & ETHICS

OK INTERNATIONAL, INC. CODE OF BUSINESS CONDUCT & ETHICS OK INTERNATIONAL, INC. CODE OF BUSINESS CONDUCT & ETHICS Statement by Chief Executive Officer Ethics are vital to OK International, Inc. and each of its employees. OK International is committed to the

More information

Code of Business Conduct

Code of Business Conduct Code of Business Conduct Unlock the Power of A System of Integrity Table of Contents Introduction 4 Patient Care 8 Privacy and Confidentiality 9 Workplace Behavior and Equal Employment Opportunity 10 Conflicts

More information

Nyack Hospital Code of Conduct. Committing to Excellence

Nyack Hospital Code of Conduct. Committing to Excellence Nyack Hospital Code of Conduct Committing to Excellence LETTER FROM THE PRESIDENT Our commitment to providing compassionate, quality healthcare has earned us the respect and trust of our patients and the

More information

BARRICK GOLD CORPORATION

BARRICK GOLD CORPORATION BARRICK GOLD CORPORATION Code of Business Conduct and Ethics Introduction Barrick s success is built on a foundation of personal and professional integrity and commitment to excellence. As a company and

More information

Delos M. Cosgrove, M.D. Chief Executive Officer and President, Cleveland Clinic

Delos M. Cosgrove, M.D. Chief Executive Officer and President, Cleveland Clinic Code of Conduct Dear Colleagues: Cleveland Clinic has a worldwide reputation for clinical excellence enhanced by innovative research and education for medical leadership. We have earned the confidence

More information

NextEra Energy Supplier Code of Conduct

NextEra Energy Supplier Code of Conduct Preface NextEra Energy, Inc. including all its employees, representatives, affiliates and subsidiaries (collectively, the Company, or we or our ) have three core values which underscore all of our business

More information

QUALITY HEALTH PLANS OF NEW YORK, INC. CODE OF BUSINESS CONDUCT AND ETHICS

QUALITY HEALTH PLANS OF NEW YORK, INC. CODE OF BUSINESS CONDUCT AND ETHICS QUALITY HEALTH PLANS OF NEW YORK, INC. CODE OF BUSINESS CONDUCT AND ETHICS Adopted as of August 8, 2011 Revised January 10, 2014-1 - INTRODUCTION About Quality Health Plans of New York, Inc. Quality Health

More information

ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Issued: November 12, 2013 ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY SCOPE This policy applies to all Magnetek, Inc. ( Magnetek ) employees, its subsidiaries and affiliates worldwide,

More information

Hartford Hospital Code of Conduct

Hartford Hospital Code of Conduct Hartford Hospital Code of Conduct Introduction to the Standards: The true foundation of Hartford Hospital has always been its commitment to providing quality care to our patients and to the communities

More information

CEVA, INC. CODE OF BUSINESS CONDUCT AND ETHICS

CEVA, INC. CODE OF BUSINESS CONDUCT AND ETHICS CEVA, INC. CODE OF BUSINESS CONDUCT AND ETHICS This Code of Business Conduct and Ethics (the Code ) sets forth legal and ethical standards of conduct for directors, officers and employees of CEVA, Inc.

More information

Hope In-Home Care CODE OF CONDUCT AND ETHICS

Hope In-Home Care CODE OF CONDUCT AND ETHICS Hope In-Home Care CODE OF CONDUCT AND ETHICS September 2014 Table of Contents A MESSAGE FROM OUR DIRECTOR... 3 INTRODUCTION TO THE CODE OF CONDUCT AND ETHICS... 4 ELEMENT 1: QUALITY OF CARE... 5 ELEMENT

More information