The HSC Health Care System Code of Conduct

1 THE HSC Health care System . Caring, Serving, Empowering Code of Conduct Dear HSC Health care System Employees, Our mission at The HSC Health care System is to provide and coordinate innovative, high quality, community-based care for individuals with complex needs and their families. HSC empowers all we serve to improve the quality of their lives. Since 1883, we have tried to meet the ever-evolving needs of our patients and members, as well as assisting their caregivers and family members to access the supports and services needed to help them achieve their best life.

2 This work happens because of the community of people who make up The HSC Health care System , and we are so pleased to have you on the team. Our staff is our greatest strength. At HSC, we believe that we can play a much broader role in empowering our families to achieve not just good, but great outcomes. To do that, every member of our staff needs the tools and information to perform at the highest standards to be successful. We ask that you to use good judgement as you go about your daily activities and assignments on behalf of the System and its patients and members.

3 If you have a concern about a particular business practice, or are unsure if a standard is being compromised, please speak up. Notify your supervisor, other leaders or the Compliance Officer. Please follow the behaviors in this Code of Conduct so that you can help the HSC Health care System continue its excellent reputation in our community. Thanks for your commitment to service at The HSC Health care System . Sincerely, Nathaniel Beers, MD, MPA, FAAP. TABLE OF CONTENTS. I. SECTION 1: PRINCIPLES OF ETHICS AND Purpose of the HSC Health care System Applicability of this Non-Retaliation Policy.

4 8. Responsibilities for Compliance Responsibilities for Questions Regarding the 10. Disciplinary Action for 10. II. SECTION 2: 11. Patient, Enrollee and Client Ethics and 11. Workplace Environment, Diversity and 12. Environmental Health and 13. III. SECTION 3: CONDUCTING 14. Conflicts of Interest/Financial Interests or 14.. 15. Referral of Patients/Improper 16. No Payment to Labor 17. Employment of 17. Safeguarding the Confidentiality and Privacy of Patients/. Enrollees/Employees' 17. Security of Electronic Information .. 18. Relationships with Subcontractors and 18.

5 Relationships with Physicians and Independent Licensed 18. Business 19. Protecting the Confidentiality of System 19. Protecting the Confidentiality of Information Owned by Others .. 20. 20. Use of Internet and Other Electronic Communication Systems .. 20. Marketing .. 21. Hiring of Former Government 21. The HSC Health care System Code of Conduct | january 2018 3. IV. SECTION 4: COMMUNICATIONS ON BEHALF OF THE System AND. COMMUNITY ACTIVITIES ..22. Communication and Media Relations ..22. Participation in Activities of Professional Organizations and Community Boards.

6 22. V. SECTION 5: RELATIONSHIP WITH COMPETITORS ..23. Compliance with Federal and Anti-Kickback and Self-Referral Statutes ..23. Trade Practices and Anti-Trust ..23. VI. SECTION 6: DOING BUSINESS WITH THE GOVERNMENT .. 24. Payment and Accounting Practices .. 24. Anti-Fraud Laws .. 24. Medicaid Requirements ..25. Federal and State Whistleblower Laws ..25. Compliance with Government Investigations ..25. No Gifts, Meals or Gratuities for Governmental Personnel .. 25. Regulatory/Accreditation/Certification Excluded Parties ..26. Political Contributions and Commenting on Political VII.

7 SECTION 7: COMPLIANCE PROGRAM ..28. Role of the Compliance Officer ..28. Reporting Compliance Issues and Concerns ..28. Acknowledgment and Certification of ACKNOWLEDGEMENT AND CERTIFICATION STATEMENT ..30. 4 The HSC Health care System Code of Conduct | january 2018 . THE HSC Health care System . MISSION STATEMENT. HSC Health care System provides and coordinates innovative, high quality, community- based care for individuals with complex needs and their families. HSC empowers all we serve to improve the quality of their lives. ORGANIZATIONAL. BELIEFS. HSC supports individuals and families to maximize their potential.

8 The following beliefs drive our work. HSC believes that: A culturally diverse community is a strength. Inclusiveness for individuals, families, and staff promotes positive outcomes. Everyone should be treated with compassion and empathy. Our skillful, dedicated, and resourceful staff is key to our success. We must continually adapt to the changing needs of our community. Increased independence is an important goal for individuals and their families. The HSC Health care System Code of Conduct | january 2018 5. SECTION 1: Principles of Ethics and Integrity Purpose of the HSC Health care System Code of Conduct The HSC Health care System ( System ) is committed to the principles of ethics and integrity in the Conduct of its business and in the provision of care and services to all.

9 The System provides and/or coordinates healthcare services to a diverse population of clients, enrollees and patients who are members of federally-funded government programs such as Medicaid. When the System provides or coordinates services to Medicaid patients, we agree to follow the governmental rules and regulations that apply to these programs. Our values provide the foundation for these principles, providing guidance to our employees and others who act on the System 's behalf. We have adopted an organizational Code of Ethics and have prepared this Code of Conduct ( Code ) to confirm and memorialize this commitment.

10 This Code outlines expectations for behavior by System employees that are required by statute, laws, regulations and/or System policies and procedures. 6 The HSC Health care System Code of Conduct | january 2018 . HSC Health care System Values Our Code is built on the System 's values, and the ways in which we demonstrate them in our work, including: A Culture of Commitment { We agree to demonstrate System values and mission in daily behavior and in interactions with patients/enrollees/clients/families, vendors, government regulators and the general public.}