Health Plus - Código de Conducta

Código de Conducta
Compliance Program Code of Conduct - Doing the Right Thing!

Table of Contents

Message from the Executive Director of Health Plus and the Health Plus Board of Directors
Introduction to the Code of Conduct
1. Non-Retaliation policy
Code of Conduct
Addressing Integrity Concerns
- Communicating Legal and Ethical Issues
- Compliance Hotline
Code of Conduct Acknowledgement

Mission and Values

Health Plus is a not-for-profit healthcare plan committed to quality healthcare and dedicated to the health and well-being of our culturally diverse communities through partnerships with members, providers, and community-based organizations.

We strive for excellence through our commitment to:

Our communities
Quality
Advocacy
Cultural sensitivity & linguistic competence
Respect and compassion
Teamwork
Members', providers', employees', and partners' satisfaction
Accessibility and responsiveness
Fiscal responsibility
Health outcomes

I. MESSAGE FROM THE HEALTH PLUS EXECUTIVE DIRECTOR AND THE BOARD OF DIRECTORS
Health Plus, as a subsidiary of Lutheran Medical Center, has a tradition of being a responsible citizen of the communities it serves. Our commitment to providing quality managed care services, fully complying with the law, and meeting the highest ethical practices for business conduce coincides with Lutheran Medical Center's standard for providing quality medical care and sets the standard for how we do business. Legal compliance and ethical conduct means doing the right thing as we go about our jobs.

The Board of Directors has adopted a Compliance Program as an affirmation of our commitment to render quality managed care services in a legal and ethical environment. This Program supports and demonstrates Health Plus' mission: Health Plus is a not-for-profit health care plan committed to quality health care and dedicated to the health and well-being of our culturally-diverse communities through partnership with members, providers, and community-based organizations. It is consistent with our Vision and Values.

This Code of Conduct is the cornerstone of the Health Plus Compliance Program. It contains the standards of behavior that each one of us at Health Plus is expected to observe while performing our jobs. Spelling out the standards helps us understand the compliance risks in each of our jobs and how to avoid them. Other elements of the Compliance Program and how it works are also described in the Code of Conduct.

Health Plus has a non-retaliation policy. Under that policy, Health Plus will not take or tolerate retaliation or retribution against any employee who, in good faith, reports a legal concern, an ethical concern or a violation of the Code of Conduct.

The Code of Conduct establishes in general terms what doing the right thing means at Health Plus. All Health Plus employees, officers, members of the Board of Directors, volunteers, and other individuals working at or on behalf of Health Plus are subject to this Code.

Please read the Code of Conduct thoroughly. Our Compliance Program depends upon everyone's participation for its continued success.

II. INTRODUCTION TO THE CODE OF CONDUCT
Health Plus is committed to providing access to quality health care in the communities we serve. To succeed in our Mission, we must maintain our members’ trust as well as the trust and respect of our employees and our business partners. This trust rests on our commitment to the highest ethical standards in every aspect of our business. To preserve this trust, we must devote ourselves to maintaining high ethical standards in our daily work activities, in our relationships with our members and business partners, in our corporate and financial operations, and, ultimately, in our provision of high quality health care services.

Health Plus business practices are founded upon a common set of values that govern our relationships with our members, providers, vendors, consultants, business partners, and one another. These values include integrity, honesty, fairness, and responsibility in all our dealings. While it is impossible to define in complete detail all conduct expected of employees, this Code of Conduct (“Code”) serves as a guide for each employee and for all those who do business with us. It supports Health Plus in fulfilling its obligations to observe the laws and public policies affecting its business. In many cases, these standards exceed the standards required by law. The Code is designed to alert employees and those who do business with us to the types of conduct expected of them. These standards enable us to identify, address, resolve and prevent potential problems.

The Code of Conduct (the “Code”) describes our ethical standards and how these standards are applied to our day-to-day activities. It is meant to be comprehensive, yet easily understood. All policies set forth in this Code are mandatory and must be followed by all Health Plus employees and all business partners. The Code, which you are encouraged to use as a reference, is intended to supplement – not replace - your individual department’s policies and procedures and/or all other Health Plus policies and procedures.

The Code is an important element of the Compliance Program. Health Plus relies upon the integrity of its employees to comply not only with the letter of the Code but also with its spirit. We depend upon each employee at all times to rely upon his or her good judgment to do the right thing. In addition to this Code, Health Plus will periodically distribute memoranda and policy statements describing compliance matters, or requiring or prohibiting specified behavior by all or some of Health Plus's employees. To the extent that these documents prohibit or require certain conduct, they should be considered part of the Code.

Failure to Follow the Code

An employee’s failure to follow the Code may result in serious consequences to the employee up to and including termination, and/or criminal charges, required reimbursement for losses or damages, and, where appropriate, reporting to a governmental authority, or, in the case of a business partner, it could mean termination of the relationship. The following are some examples of violations that will be subject to disciplinary action:

Any employee or officer who violates this Code or applicable laws and regulations, or Health Plus policies and procedures, or who directs others to do so;
Any employee or officer who deliberately withholds relevant information, or knowingly provides false information, concerning a violation of this Code or applicable laws and regulations, or Health Plus policies and procedures;
Any employee or officer who retaliates, directly or indirectly, against another employee for reporting a suspected violation of this Code or applicable laws and regulations, or Health Plus policies and procedures, or failing to assist or cooperate in an investigation of a suspected violation.
• The violator’s manager to the extent that the circumstances of a violation reflect themanager’s disregard of the Code or applicable laws and regulations or Health Plus policies and procedures.

This Code will be enforced at all levels, fairly and without prejudice.

At-Will Employment

This Code does not create a contract of employment either expressly or implied and nothing contained in this Code is intended to alter a person’s status of “employment-at-will” with Health Plus to any other status.

A. NON-RETALIATION POLICY

Any employee who raises concerns or allegations of possible violations of the Code of Conduct, policies/procedures, laws, or regulations will be received openly and courteously. There will be no direct or indirect retaliation or punishment against anyone who, in good faith, raises concerns.

Reporting

Supervisors are required to set an ethical example for their employees and employees are encouraged to address any questions or concerns they might have with their Supervisor first. However, there are alternative corporate resources available, as outlined in the section “Communicating Legal and Ethical Issues”.

III. CODE OF CONDUCT
A. QUALITY OF SERVICE
Our members are the reason we are in business. Health Plus is committed to providing access to quality, cost-effective healthcare services that respond to individual, family and community needs. Moreover, all providers, and vendors who contract to provide services for Health Plus, are required to operate their business in accordance with this Code. Thus, to the extent applicable, contractors and vendors agree to abide by this Code and its standards, and understand that the term "we" as written herein, includes them.

We will serve our members and each other in a professional manner with integrity, honesty, courtesy and respect.
We are expected to communicate openly, honestly and professionally with members, providers, and regulatory agencies, and each other.
We recognize our members’ right to receive appropriate quantity and quality healthcare services without discrimination based on race, creed, gender, national origin, sexual orientation, age, physical or mental handicap or disability, type of illness or condition, need for health services, or source or amount of payment.
We shall allow only qualified, properly licensed and credentialed individuals, practicing within the scope of their license or credentials, to provide healthcare services to our members.
We shall base utilization review decisions upon objective criteria and apply those criteria fairly and consistently. Clinical determinations to authorize or deny coverage will be made only by licensed, certified or registered health care professional with current valid license.
We have a duty and responsibility to recognize any shortfall or error, no matter how small or insignificant. Any person who sees or hears of a problem or issue must bring it to the attention of an appropriate level of management or the Compliance Department.
Employees, providers, vendors and contractors should report any incidents of inferior health care services provided to members to their supervisors or to the Compliance Department.

B. MARKETING PRACTICES

We are committed to promoting Health Plus, educating consumers ethically, providing sufficient information about health insurance options and helping members make informed choices. We must comply with all laws, State and City regulations, contractual requirements on marketing practices and consumer protection, and industry marketing guidelines.
All marketing materials must be approved internally and then by the appropriate State and City agencies prior to use.We must be careful and honest in marketing. The following activities are strictly prohibited:
- Deceptive marketing practices;
- Door-to-door solicitation of potential members;
- Unsolicited personal contacts with potential members, including cold calls;
- Direct marketing or distribution of materials in hospital emergency rooms;
- Distributing marketing and sales materials that lack appropriate approval to potential members;
- Misuse of marketing or competitor information;
- Misleading or discriminatory enrollment practices;
- Misrepresentations of any kind;
- Tampering with documents, “coaching” potential members or allowing potential members to tamper, alter or “create” documents or otherwise engaging in fraudulent activities.
Employees must immediately report any prohibited marketing practices used by any Health Plus employee, provider or other entity associated with Health Plus to their supervisor or the Compliance Department. All supervisors must report such issues to their Directors and/or Chiefs.

C. CONFIDENTIALITY
We are committed to using and disclosing information only for its intended purposes. Confidential and proprietary information will only be accessed, used, or disclosed by employees as needed to perform specific job responsibilities.

We are responsible for holding in strict confidence any and all confidential and proprietary information pertaining to Health Plus and its members, employees, providers, and other affiliates.
Confidential information includes Individually Identifiable Health Information, which is defined as any health information, including demographic information collected from an individual, transmitted or maintained in any form or medium, that:
- Is created or received by Health Plus; and
- Relates to the past, present, or future physical or mental health or condition of a member; the provision of health care to a member; or the past, present, or future payment for the provision of health care to a member; and
- Identifies the member; or could reasonably be used to identify the member.

The information deemed confidential and owned by Health Plus includes, but is not limited to, the following:

Data and Documents
Contracts
Medical Records
Member Files
Claims Data
Employee Files
Human Resources/Employment Records
Company Directories
Strategic Plans
Methods of Operation
Business Practices
Policies & Procedures
Board of Director’s Information
Information Systems
Provider records and files
Financial Data/Reports
All other Individually Identifiable Health Information

If you don’t know or are not sure if something is confidential – ask!

Member Information
We will not disclose Protected Health Information outside Health Plus unless we have proper written authorization to share it, in accordance with Health Insurance Portability and Accountability Act (HIPAA) and other applicable Federal and State law. We will follow Health Plus policies and procedures for the handling of Protected Health Information. These requirements continue to apply even after we leave Health Plus employment.

Employee Information
Do not share your or other employee’s information. Information about employees’ salary, Social Security Number, age, status, type of leave or banking information should not be shared with third parties, unless required for business operations. Some of our employees are also our members and should be afforded the same protections as all of our members.

Intellectual Property and Trade Secrets
Intellectual property and trade secrets include all ideas, inventions, discoveries, improvements and innovations. Health Plus owns all intellectual property that we make, create, develop, write or conceive either on our own or with another person while employed by, or contracted with Health Plus, if it relates or pertains in any way to Health Plus’ business. We will not disclose information about Health Plus’s Intellectual Property and Trade Secrets to people outside Health Plus. Please see the “Safeguarding Health Plus Property and Interests” Integrity Standard for more information about Health Plus’s Intellectual Property and Trade Secrets.

Health Plus-Owned Business Information and “Insider” Information
We will not give confidential or non-public Health Plus information to people outside Health Plus, such as competitors, suppliers, or outside contractors without proper authorization. This includes financial information, member lists, computer data, computer programs, as well as descriptions of Health Plus processes, policies, or operations. We will not discuss Health Plus’s potential business relationships, purchases, mergers or acquisitions or other organizational changes either internally or with people outside Health Plus.

Passwords
We will protect and maintain the confidentiality and integrity of information used to access our systems, including but not limited to, passwords and other personal security codes. Keep passwords and other personal security codes confidential. We recognize that we are each responsible for the actions resulting from the use of our passwords. Do not let others use your password or computer, while logged on.

Physical Safeguards
We will maintain confidential and Health Plus business documents and information under strict control at secure work-site locations, stored in lockable file cabinets or offices. Employees will protect confidential materials from disclosure when copying, faxing, and mailing, e-mailing, or speaking to others. Fax machines that are used to transmit or receive confidential materials should be located in areas accessible only to staff authorized to see such materials.

D. COMPLIANCE WITH LAWS AND REGULATIONS
When we accept government contracts, we have an obligation to ensure that we administer those contracts and deliver our products and services in a manner that complies with those contracts, as well as our own high standards of honesty, integrity and excellence. Health Plus employees must know the rules, regulations and policies guiding operations of their work areas.

Contracts

All contracts entered into on behalf of Health Plus must be reviewed and approved by the Legal Department. We shall ensure knowledge of and compliance with these contracts and Federal and State regulations guiding government programs in which Health Plus participates.
All contracts must be signed by an “authorized” signator; there is a clear and limited list of who may sign contracts on behalf of Health Plus. Unless you are authorized, never sign a contract on behalf of Health Plus.

Accuracy of Records and Billing

We shall ensure that all statements, communications, and representations are accurate, complete, truthful and timely, and comply with applicable laws and regulations.
We shall not tolerate known false statements to a government agency or other payor. Any employee who makes a deliberate misstatement to a government agency or other payor will risk criminal penalties and termination of employment.
We will cooperate with all reasonable requests for information from government and regulatory agencies. In so doing, it is essential that the legal rights of Health Plus and of our personnel involved be protected. Any governmental or regulatory inquiry, subpoena, or other legal document regarding our business, received at home or at the work place must be forwarded to the Legal Department immediately.
We must ensure that payments or other benefits to providers be supported by proper documentation that the services contracted for were, in fact, provided or, in the case of capitated agreements, available.
We will follow appropriate procedures governing the retention and destruction of records consistent with applicable laws, regulations, contracts, company policies and business needs. We must never misrepresent facts, falsify or suppress records that may be relevant to a legal action, financial or governmental investigation. We will consult with and follow the instructions of the Legal Counsel.
We will establish, maintain, support and follow internal controls designed to provide reasonable assurance that transactions are authorized and that data is recorded and presented in a manner that is accurate, complete, current and reliable.

Kickbacks

We do not offer payment, gratuities, or favors to any employees, providers, or vendors, current, former or potential, for referrals of
members.
We will not offer or give gratuities or anything of value to any employee or representative of a government agency that regulates or
audits Health Plus operations or with which Health Plus has or is seeking to obtain a contract.
We are prohibited from accepting or giving gifts, gratuities or anything beyond common business courtesies of nominal value.
Under no circumstances will we accept or give kickbacks when obtaining or awarding contracts, services, referrals, goods, or business. (See the Gift, Gratuities & Kickbacks section)

Fair competitions

We are committed to a policy of vigorous, lawful and ethical competition, which is based on the quality of our products and services. We will maintain the trust of our members, providers and communities we serve by providing high-quality services in a fair, ethical and legal manner.
Health Plus employees will not use confidential information of its competitors to seek unfair advantage in the marketplace. Any employee who has come into possession of such information is required to immediately report it to the Legal Counsel.

Work Environment

We must comply with Federal and State employment laws applicable to Federal and State contractors, prohibiting discrimination based on race, creed, gender, national origin, sexual orientation, or age. Health Plus is an Equal Opportunity Employer.
We must not discriminate against individuals in the terms and conditions of employment based on handicap, disability or perceived disability.
Health Plus shall not hire or do business with individuals or entities that have been debarred or excluded from participation in State or Federal health care programs.
We shall not be required to lower our professional standards, judgment or objectivity to another individual.
Considerable differences of opinion in professional judgment should be referred to appropriate management levels for resolution.

Failure to comply with these requirements and terms of our government contracts may jeopardize Health Plus’s ability to participate in government programs; violator(s) will be subject to the full range of disciplinary actions, up to and including termination. Violations, or the suspicion of a violation, must be immediately reported to a supervisor or the Health Plus Corporate Compliance Department.

E. FRAUD AND ABUSE
Health Plus’s reputation for integrity and our continued success depend on each of us being honest and following all laws and regulations. Fraud, dishonesty or criminal conduct on the part of any employee, officer or director or anyone doing business with the company will not be tolerated.

Fraud is knowingly lying, cheating, or withholding truth that results in an unauthorized benefit. Fraud includes but is not limited to:
- Any incentive given or received in exchange for referral of members or patients;
- Providing false or misleading information to become a member;
- Engaging in fraudulent or misleading marketing practices;
- Providing false or misleading information to obtain payment;
- Submitting false, fraudulent or misleading claims such as:
- Claims for services not delivered;
- Claims for a service different from the service actually delivered or received;
- Claims that do not follow applicable legal requirements.
Abuse refers to the practices that cheat or ‘game the system” and result in unnecessary cost to the State, Federal government, or Health Plus. These include:
- Providing more or less services than are medically necessary;
- Payment or billing for services that are not medically necessary
- Failure to meet professionally recognized standards for quality health care.
We must avoid situations or conduct that involves or consists of actual or potential fraud and/or abuse in our internal operations.
If you detect or suspect an actual or potential fraud or abuse situation, you must immediately discuss it with your director or the Corporate Compliance Department. You will be expected to abide by Health Plus's decision on resolving/reporting the fraud or abuse.
Each report will be thoroughly investigated and violations of law may be reported to State and law enforcement agencies, as appropriate.

F. CONFLICTS OF INTEREST
We are expected to serve our members on behalf of Health Plus at all times. We will avoid any conflicts between our private interest and the best interests of Health Plus and its members.

We must avoid situations where our personal interests could conflict, or reasonably appear to conflict, with the interest of Health Plus. We must be free of actual, apparent or potential conflicts of interest when dealing with persons or business entities on behalf of Health Plus. We must award business solely on merit, getting the best value for Health Plus, and wherever practical, on a competitive basis. A conflict of interest occurs whenever an employee permits the possibility of direct or indirect personal gain to influence his or her judgment, decisions or actions regarding Health Plus business. Employees should disclose potential conflicts of interest to their Director, the Director of Human Resources, the Corporate Compliance Office or Legal Counsel.

Nepotism* and other Forms of Favoritism

You may not have direct or indirect responsibility for the hiring or supervision of a family member.

Employment of family members is permitted so long as employees are not reporting directly or indirectly to each other. We must disclose possible conflicts of interest for resolution. A family member generally includes an employee’s:
- Spouse or domestic partner
- Grandchild
- Parent/Stepparent
- In-laws
- Children
- Corresponding immediate family members of any employee’s spouse or domestic partner
- Siblings
- Grandparent
We may not use information that comes to us in the course of employment for personal investment or gain, nor can we provide this type of information to family members or others, nor can we provide this type of information to family members or others.

*Nepotism means favoring relatives or personal friends because of their relationship rather than because of their abilities.

Gifts, Gratuities and Kickbacks

We are prohibited from accepting or giving gifts or gratuities beyond common business courtesies of nominal value. Under no circumstances will we accept or give kickbacks when obtaining or awarding contracts, services, referrals, goods, or business. A kickback means to willfully offer, receive, request or pay anything of value in order to persuade or reward referrals of business including goods or services.
We should not accept gifts, payments, fees, services, discounts, valued privileges or favors (even those of nominal value) which would, or might appear to, improperly influence our decision-making on behalf of Health Plus.
We have an affirmative duty to avoid accepting or providing benefits that could be interpreted as conflicting with Health Plus's legitimate business and interests, including, without limitation, payments, fees, services, discounts, valued privileges or favors where these would, or might appear to, improperly influence the performance of our duties.
We may not accept cash gifts, including checks, honorariums or money orders of any amount. However, gifts of nominal value ($100 or less) and reasonable meal and entertainment courtesies are not prohibited. Non-cash gifts that exceed $100 in value may not be accepted. Offers of non-cash gifts in excess of $100 must be reported to a Director. Gifts exceeding $100 value must be turned over to the Compliance Department or a Chief.
Gifts given internally should not exceed the nominal value of fifty dollars ($50). Employees are discouraged from giving gifts to management and in no instance shall any gift to management exceed the value of twenty five dollars ($25) unless approved in advance by a Chief.
At a vendor’s invitation (not an employee’s request) an employee may accept a meal, refreshment, attendance at a local theater or sporting event and/or other entertainment in connection with furthering Health Plus’s business interest. Provided that the business courtesy is:
- of a reasonable value,
- is offered infrequently,
- is customary and a part of normal business practices,
- it imposes no sense of obligation on the giver or recipient,
- it involves no special treatment, such as free services or special discounts,
- it is not a loan or payment,
- it would not be perceived as likely to influence the employees “business judgment”; and
- it would be appropriate to reciprocate in a similar manner.
- In most circumstances a business representative of the vendor should be in attendance with the employee.
- Gifts or items of value must never be offered to government employees.
- Gifts to or from members or potential members should not be given or accepted.

Political Activity

Employees are encouraged to vote and actively participate in the political affairs of their communities. This activity, however, must take place on your own time and at your own expense. Health Plus shall not participate in or intervene in (including the publishing or distribution of statements) any political campaign on behalf of (or in opposition to) any candidate for public office. Employee must not associate Health Plus with or imply Health Plus’s endorsement of personal political activity.
Health Plus corporate funds may not be expended in support of or in opposition to any political candidate or political party.

Outside Employment

We shall not become involved, directly or indirectly, in outside commercial interests, which could improperly influence our actions on behalf of Health Plus. This may include being an officer, director, manager, employee or consultant of a competitor, vendor or contractor of Health Plus. We may not engage in any outside activity that impairs our job performance or interferes with our ability to perform our duties adequately.

G. WORK PLACE CONDUCT AND EMPLOYMENT PRACTICES
Health Plus is committed to maintaining a work environment where we treat each other with honesty, dignity, and respect. Health Plus values diversity and the cultural contributions of all employees, regardless of their position, sexual orientation, family status, age, race, sex, disability, religion, or national origin. All employment practices are based on ability and performance.

Health Plus seeks to be a responsible employer by providing opportunities for professional satisfaction, pride of work, and career growth for all employees.
We have a fundamental responsibility to show appropriate respect for and consideration of one another, regardless of position, station or relationship.
Health Plus will not tolerate sexual advances, actions, comments, inappropriate physical contact or any other conduct that is intimidating or otherwise creates an offensive or hostile work environment.
Health Plus respects the right to work in an environment free from harassment and discrimination, where employee’s privacy and dignity are valued and protected from offensive, obscene, or threatening behavior.
Health Plus maintains a drug free work place. We will not tolerate possession, distribution, or use of illicit drugs or alcohol or an employee being under the influence of illicit drugs or alcohol while on duty.
Health Plus shall conform to the standards of our professions and exercise judgment and objectivity in the performance of our duties. Any differences of opinion in professional judgment should be referred to appropriate management levels for resolution.
Employee safety is important to Health Plus. Health Plus will make a special effort to protect and help keep safe its employees who work in or outside of Health Plus offices. Health Plus has specific internal policies and procedures to address employee safety and Health Plus is committed to working cooperatively with employees to resolve safety concerns.
We shall not permit any action of retaliation or punishment to be taken against an employee who in good faith reports a violation or suspicion of a violation of a law, regulation, company policy or the Code.

H. SAFEGUARDING HEALTH PLUS PROPERTY AND INTERESTS
We will use and maintain Health Plus assets with the care and respect, guarding against misuse, waste, abuse, loss and theft. Health Plus assets include, but are not limited to, corporate data, business strategies and plans, financial data, and other trade secrets or confidential information about Health Plus business or its employees. Health Plus property also includes all equipment, furniture, vehicles, office supplies, corporate funds, credit cards, employee time, and computer supplies and software. In addition:

We shall consider any information concerning the business affairs of Health Plus, our suppliers, employees, or personnel, as confidential. No information may be shared except as authorized or in the performance of our duties.
We shall dispose of surplus, obsolete or junked property in accordance with company policies and procedures. Unauthorized appropriation or disposal of property is a misuse of assets.
We shall not engage in financial misconduct, including any activity involving Health Plus property that results in an improper financial gain to the employee from outright theft of property, embezzlement of money, or the use of money belonging to Health Plus for anything other than an authorized purpose. This also includes an employee knowingly turning in false time records, or the unauthorized use of company equipment or property.
We are expected to exercise reasonable care to protect our personal property while on Health Plus premises or in the field.

Intellectual Property and Trade Secrets

Intellectual property and trade secrets include all ideas, inventions, discoveries, improvements and innovations. Health Plus owns all intellectual property that we make, create, develop, write or conceive either on our own or with another person while employed by or contracted with Health Plus.

Unauthorized Software

We follow State and Federal laws pertaining to copyright protection. This includes duplication of print materials, as well as duplication of licensed computer software.
We shall never copy computer software. The unauthorized copying or use of software could be a violation of federal copyright laws and could result in civil and/or criminal liability.
We shall not take any Health Plus commercial software products home for personal use.

Use of Internet and other Electronic Media

All communication systems, electronic mail, Internet, phones, voice-mail, fax and Health Plus Intranet are the property of Health Plus and are to be used for business purposes only.
Company systems may not be used to send chain letters or personal broadcast messages.
Company systems may not be used for viewing, sending or receiving offensive or inappropriate materials.
No communications are private and all are subject to review by Health Plus management.

IV. ADDRESSING INTEGRITY CONCERNS
Healthcare is governed by complex, demanding and changing laws, rules and regulations. Sometimes application of these rules and regulations creates uncertainty and questions. The Health Plus Code of Conduct gives us the tools to help resolve any concerns or
questions one may have about business ethics, integrity, and Health Plus expectations.

Open discussion of issues and concerns by all employees and management without any fear of retaliation is essential to the success of the Corporate Compliance Program. For this reason, Health Plus has implemented a non-retaliation policy to protect those who report legal or ethical issues in good faith. Health Plus encourages you to discuss legal and ethical issues that arise while performing your job.

We have a responsibility to perform our job in an honest and ethical way. We have an affirmative requirement to report the knowledge or suspicion that we, in good faith, believe may be a violation of any applicable laws, regulations, policies or Health Plus Code of Conduct. Health Plus has an absolute policy against any retaliation for bringing forward a good faith concern. Violators of this policy will be subject to disciplinary action.

All supervisors and managers are charged with ensuring that all their subordinates receive annual compliance training.

Communicating Legal and Ethical Issues

If you are confronted with a compliance or ethical dilemma, ask yourself the following questions:

Does it seem like a law, regulation or Health Plus policy is being violated?
Does the behavior/act at issue appear to be unacceptable or unethical to you?
Does it seem inconsistent with Health Plus values and the Code of Conduct?

If your answer to any of these questions is yes, then, it's time to act!

Step 1*

Discuss the issue with your immediate supervisor who knows you and the issues in your workplace. Your supervisor is in a good position to understand your concerns. Give your supervisor an opportunity to resolve the issue. Your supervisor is responsible for upholding the Health Plus Code of Conduct in your work area. If you still have concerns after talking with your supervisor or if you are not comfortable discussing the issues with your supervisor, go to the next step.

Step 2*

Discuss the issue(s) with the next management level. If you have raised an issue and you believe it did not get proper attention or if your supervisor cannot find the appropriate answer(s), or if the issue concerns wrongful or inappropriate conduct on the part of your supervisor, you may relate your concerns to the next management level.

Step 3*

If your supervisor or next level manager is unable to resolve the issue satisfactorily, you can contact others to help you resolve your issue to your satisfaction. Other Health Plus personnel available to you include the Director of Human Resources, the Legal Department, the Compliance Department.

Step 4*

If you do not feel comfortable discussing your issue(s) with your supervisor or manager, and you have a compliance issue, you may call the Compliance Hotline. The Compliance Hotline is available twenty-four (24) hours per day, 365 days per year. The toll free number is:

(800) 826-6762

All calls to the hotline may be made anonymously and without fear of retaliation. The calls are not traced and the information is treated in a confidential manner, subject to the limits imposed by law. Employees are encouraged to provide as much information as they know in order to assist with further investigation. Careful efforts will be made to ensure that investigations are handled confidentially.

The Hotline is intended to supplement the existing internal communication channels. It is not intended to replace our local management team, Senior Management or other corporate resources. The Hotline is available when you believe that you have exhausted normal channels of reporting problems.

Calls are handled confidentially and the caller is protected from any form of retaliation.
Anyone attempting to retaliate against an employee who calls the Hotline in good faith will be subject to disciplinary action, up to and including termination of employment.

• Please note you may always skip a step so that you can get immediate help with your concern.

If your supervisor or next level manager is unable to resolve the issue satisfactorily, you can contact others to help you resolve your issue to your satisfaction. Other Health Plus personnel available to you include your human resources representative, the Legal Department, the Compliance Officer, and/or a senior manager.

V. CODE OF CONDUCT ACKNOWLEDGMENT

I have received, read and understand the Health Plus Code of Conduct.
I understand that all employees of Health Plus, including me, are expected to abide by the Code of Conduct and that it is not a guarantee of my employment with Health Plus.
I understand my responsibility to report questions or concerns regarding compliance with laws, regulations, contract provisions, or Health Plus policies to my supervisor, the Director of Human Resources, the Corporate Compliance Department or the Hotline.
I understand that there will no be retaliation for raising a compliance issue in good faith.5. I understand that any violation of the Code of Conduct may result in corrective action and/or disciplinary action up to and including termination.
I understand that my failure to cooperate in a compliance investigation can be grounds for termination.

CORPORATE COMPLIANCE HOTLINE
(800) 826-6762
335 Adams Street, 26th Floor, Brooklyn, NY 11201