Policy
We will comply with all federal, state,
and local laws and regulations. We are each responsible
for ensuring our own compliance with laws, regulations and
contractual obligations that are applicable to the Company.
If we perform services for or work on a government contract,
e.g., the Federal Employee Program, Indian Health Service
and Medicare, it is our responsibility to know the terms
of that contract and all related policies and procedures.
Any questions or concerns regarding specific laws, regulations,
or any legal issue should be promptly brought to the attention
of the Legal Department.
All contracts entered into on behalf of the Company must
be executed in accordance with the Company’s then
current Execution of Instruments Policy. Individuals executing
such contracts are responsible for ensuring that such contracts
are consistent with Company policies and are, in the individual’s
business judgment, in the best interest of the Company.
In addition, according to Company policies and procedures
all contracts entered into on behalf of the Company must
be reviewed and approved by the Legal Department to ensure
compliance with applicable laws and regulations.
Questions & Answers
Q. My Supervisor has directed me to
do something that I believe is against the law. I’m
afraid that if I don’t do what I am told, my job will
be in jeopardy. What should I do?
A. Discuss the situation with your Supervisor to
be certain that you both understand the facts of the situation
and that he or she is fully aware of your concerns. If that
conversation does not resolve the matter to your satisfaction,
bring your concern to a higher level Supervisor or to the
Legal Department. They will assist you in reaching the right
answer. You may also call our Corporate Integrity HOTLINE
to express your concern anonymously. Do not jeopardize your
job, your co-workers’ jobs or the Company’s
future by taking part in what you believe may be an illegal
or unethical activity. There are no circumstances where
breaking the law would be acceptable to the Company.
Q. I have been working with an outside vendor to
finalize a contract. Once legal has signed off on the language
of the contract, can I sign the contract on behalf of the
Company?
A. All contracts entered into on behalf of the
Company must be executed in accordance with the Company’s
then current Execution of Instruments Policy. Individuals
executing such contracts are responsible for ensuring that
such contracts are consistent with Company policies and
are, in the individual’s business judgment, in the
best interest of the Company.
Remember, if you do not understand, or if
you have any questions concerning, this Integrity Standard
or any other part of the Code, contact your Supervisor,
a higher level Supervisor, any of the Corporate Resources
or call the Corporate Integrity HOTLINE
(1 800 838-2552).
Remember, if you do not understand, or if you have
any questions concerning, this Integrity Standard or any
other part of the Code, contact your Supervisor, a higher
level Supervisor, any of the Corporate Resources or call
the Corporate Integrity HOTLINE (1 800 838-2552).
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Conduct Page
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