TABLE OF CONTENTS
ARTICLE 1 DEFINITIONS
ARTICLE 2 INTRODUCTION
2.1 Scope of Compliance Program
2.2 Program Objectives 1
ARTICLE 3 COMPLIANCE RESPONSIBILITIES AND OVERSIGHT
3.2 Compliance Officer
3.3 Compliance Taskforce
3.5 Outside Parties
3.6 Outside Legal Counsel
ARTICLE 4 ANNUAL RISK ASSESSMENT AND COMPLIANCE WORK PLAN
4.1 Development of Risk Assessment and Compliance Work Plan
4.2 Risk Areas
4.5 Training on New Risk Areas
ARTICLE 5 AUDITING AND MONITORING
5.2 Annual Audit Plan
5.3 Periodic Audits
ARTICLE 6 EDUCATION, TRAINING AND ATTESTATION
6.2 General Training
6.3 Compliance Attestation Form
6.4 Specialized Training
6.5 Communication of Changes to Code of Conduct
6.6 Other Compliance Communication Efforts
ARTICLE 7 REPORTING, RESPONSE AND PREVENTION
7.1 Obligation to Report Suspected or Actual Noncompliance
7.3 Nonretaliation Policy
7.4 Reporting Mechanisms
ARTICLE 8 ENFORCEMENT AND DISCIPLINE
8.1 Enforcement of Compliance Plan and Code of Conduct
8.2 Reporting Violation of Laws
8.3 Compliance as an Element of Job Performance
ARTICLE 9 REVIEW AND APPROVAL OF COMPLIANCE MATERIALS
9.1 Code of Conduct
9.2 Compliance Plan
ARTICLE 10 CONCLUSION
As used in this Compliance Plan, the following definitions apply:
"Anodyne" shall mean Anodyne, LLC.
"Code of Conduct" shall mean the Anodyne Code of Conduct.
"Compliance Officer" shall mean the individual appointed by the Manager (defined below) who is responsible for implementing and supervising the Compliance Program.
"Compliance Plan" shall mean this written plan of compliance that is part of the Compliance Program (defined below). The Compliance Plan includes the Code of Conduct (collectively, the Compliance Plan and the Code of Conduct are referred to herein as the "Compliance Materials").
"Compliance Program" shall mean the overall program of compliance adopted by Anodyne, as described in the Compliance Plan and the Code of Conduct, and implemented through various other policies and procedures, and corporate practices.
"Compliance Taskforce" shall mean the ad hoc committee that is formed by the Compliance Officer, from time to time, to assist the Compliance Officer in addressing potential problems that are identified.
"Employees" shall mean individuals who are employed by Anodyne.
"Manager" shall mean the Manager of Anodyne.
"Outside Parties" shall mean any non Employee supplier or other third party with which Anodyne contracts or otherwise agrees with to provide, furnish or arrange for any component of services or items directly or indirectly payable by a federal health care program.
2.1 Scope of Compliance Program. The Compliance Program, as described in the Compliance Materials, governs the operations of Anodyne.
2.2 Program Objectives. Anodyne is committed to developing and implementing practices, policies and procedures to create and foster an organizational culture that encourages open communications regarding compliance issues, without fear of retaliation, which is embraced and trusted by Anodyne's Manager, Employees and Outside Parties, as applicable. To that end, and in furtherance of its overall Compliance Program, Anodyne shall:
(a) Develop, implement and maintain written policies and procedures addressing Anodyne's commitment to compliance, including specific policies and procedures addressing areas of risk and vulnerability to Anodyne.
(b) Establish and maintain a system for routine/continuous identification and assessment of compliance risk areas within Anodyne through the use of periodic reviews, audits, and other practices. As described in Article IV below, the Compliance Officer, directly or through his or her designee, will periodically monitor and/or conduct specific reviews of the risk areas impacting Anodyne's business including, without limitation: the Federal Anti-Kickback Statute; Medicare Approval; Exclusion Screening; Sunshine Act; Marketing and Sales Requirements; and other potential compliance risk areas that may arise from complaints, external reviews and other risk assessments.
(c) Appoint a Compliance Officer who is responsible for the oversight and implementation of the Compliance Program, and maintenance of the Compliance Materials and related policies and procedures.
(d) Provide regular, effective education and training to Employees regarding the Compliance Program and the Compliance Materials.
(e) Establish effective lines of communication between the Compliance Officer and Employees.
(f) Create and implement programs designed to encourage and monitor good faith participation in the Compliance Program consistent with Anodyne's expectation that Employees will raise questions and report concerns relating to adherence to Anodyne's Compliance Materials, and related compliance policies and procedures.
(g) Institute effective procedures for receiving reports concerning possible violations of relevant laws and regulations, the Compliance Materials or any related compliance policies and procedures, and strictly enforce Anodyne's nonretaliation policies and procedures.
(h) Design and maintain procedures for responding to and investigating potential compliance issues raised by any individual, entity or agency, which include direction regarding the proper response to noncompliance, such as corrective action, repayments or preventive measures.
(i) Utilize audits and monitoring to evaluate compliance, identify new risk areas and assist in reducing instances of noncompliance.
(j) Develop procedures to prevent the employment or retention of excluded individuals or entities, and develop processes to ensure appropriate disciplinary action is taken against persons who have violated the Compliance Materials.
COMPLIANCE RESPONSIBILITIES AND OVERSIGHT
3.1 Manager. The Manager has ultimate responsibility for the Compliance Program. In that role, the Manager has charged the Compliance Officer with the responsibility of implementing, evaluating and monitoring adherence to the Compliance Program. The Manager shall receive, at least annually, a report from the Compliance Officer on the status of the Compliance Program or specific compliance activities or issues. The Manager shall ensure that appropriate resources are allocated as part of Anodyne's annual budget to enable the implementation and effective functioning of the Compliance Program.
3.2 Compliance Officer. In addition to the duties mentioned in the Compliance Officer's job description, the Compliance Officer is responsible for implementing, and evaluating and monitoring the effectiveness of, the Compliance Program. The Compliance Officer is accountable to the Manager in the performance of his or her duties, and shall report directly to the Manager regarding: (a) the status and effectiveness of the Compliance Program; (b) scheduled audits of billing and quality of care issues; (c) communication of the Compliance Materials, including general and specialized education and training performed; (d) reported violation(s) of the Compliance Materials and corrective actions taken related to actual violations; (e) annual auditing and monitoring activities; (f) enforcement activities; and (g) coordinating quarterly screening checks of the U.S. Department of Health and Human Services, Office of Inspector General ("OIG") List of Excluded Individuals/Entities ("LEIE"). The Compliance Officer shall be responsible for reporting at least annually to the Manager on the status of the Compliance Program, including specific compliance activities or issues.
The Compliance Officer shall also be responsible for developing and implementing policies and procedures that adequately address areas of potential and actual compliance risk, and ensuring that existing policies and procedures are reviewed and revised as necessary. At a minimum, such policies shall address the high risk areas identified in the risk assessment process.
Additionally, the Compliance Officer shall be responsible for ensuring that there are appropriate mechanisms in place to encourage and support the reporting of compliance concerns and to ensure compliance with Anodyne's nonretaliation policies and procedures.
3.3 Compliance Taskforce. The Compliance Taskforce is an ad hoc committee that is formed by the Compliance Officer, from time to time, to assist the Compliance Officer in addressing potential problems that are identified. Whenever formed, the Compliance Taskforce shall meet as often as necessary to effectively support the Compliance Officer. The members of any Compliance Taskforce may change for each new problem that is identified, except that the Compliance Officer shall always chair the Compliance Taskforce.
3.4 Employees. All Employees, including the Manager and the Compliance Officer, are responsible for:
(a) Reviewing the Code of Conduct;
(b) Completing all required general and specific compliance training;
(c) Signing a compliance attestation form certifying that he or she: (i) has read the Code of Conduct; (ii) will comply with the Code of Conduct, including the duty to report noncompliance with same; (iii) has completed the requisite compliance training or education sessions regarding the Compliance Materials; (iv) is not aware of any unreported noncompliance, violations, or any other issues or concerns related to compliance; and (v) understands that he or she may be subject to discipline for failure to abide by the Code of Conduct;
(d) Performing all duties and job responsibilities in accordance with the Code of Conduct, all relevant Anodyne policies and procedures, and all applicable laws and regulations, and that such performance is a condition of continued employment and adherence to the Code of Conduct will be considered as part of performance evaluations;
(e) Reporting suspected violations of the Code of Conduct, relevant Anodyne policies or procedures, or applicable laws or regulations, as described herein; and
(f) Cooperating and participating in all audits, investigations or reports undertaken as a part of the Compliance Program.
3.5 Outside Parties. A copy of the Code of Conduct will be made available to Outside Parties. As applicable, Outside Parties are expected to comply with the Code of Conduct while providing services to Anodyne. Outside Parties also are expected to report suspected violations of the Code of Conduct or applicable laws or regulations and must cooperate and participate, as reasonably requested, in audits and investigations undertaken as a part of the Compliance Program.
3.6 Outside Legal Counsel. The Compliance Officer is authorized to engage legal counsel, where appropriate, to assist in the implementation, operation and modification of the Compliance Program. As appropriate, the Compliance Officer, and any other representative of Anodyne working with legal counsel, shall make every effort to preserve and maintain the attorney client privilege.
ANNUAL RISK ASSESSMENT AND COMPLIANCE WORK PLAN
4.1 Development of Risk Assessment and Compliance Work Plan. The Compliance Officer is responsible for developing an annual risk assessment for Anodyne. The objective of the annual risk assessment is to identify and prioritize actual or potential areas presenting compliance concerns and to recommend measures to address such concerns. Taking the results of the annual risk assessment into consideration, the Compliance Officer shall develop an annual compliance work plan, which shall include requirements for auditing and monitoring of, and training on, areas identified as high risk.
4.2 Risk Areas. The annual risk assessment shall include a review of actual or potential risk areas identified: through internal or external audits; in the OIG's annual Work Plan, Fraud Alerts or other published compliance guidance; or otherwise by the Compliance Officer. The list of risk areas below is a compilation of potential risk areas that may be subject to the annual risk assessment, as determined to be appropriate by the Compliance Officer. This list is not meant to be exhaustive, and other areas of risk may be identified and assessed as deemed necessary by the Compliance Officer or the Manager:
(a) The Federal Anti Kickback Statute. This risk area includes the exchange (or offer to exchange) of anything of value, in an effort to induce (or reward) the referral of items or services for which payment may be made, in whole or in part, under a federal health care program. This risk area may be implicated by relationships with both physicians and beneficiaries. For example, this risk area may be implicated if Anodyne offers or provides gifts, free services, or other incentives or things of value to patients, relatives of patients, physicians, podiatrists, or other potential referral sources for the purpose of inducing referrals. This risk area may also be implicated if Anodyne offers to pay a referral source more than fair market value for space rented to store items or supplies.
(b) Medicare Approval. This risk area includes the distribution or sale of diabetic shoes or inserts that do not meet the Medicare Quality Standards or inserts that have not obtained coding verification from the Pricing, Data Analysis and Coding ("PDAC").
(c) False Claims Act. This risk area includes promoting the submission of false claims to Medicare. For example, this risk area may be implicated if Anodyne falsely promotes a product that does not comply with Medicare standards, or if Anodyne violates that federal anti-kickback statute, thus causing false claims to be made.
(d) Exclusion Screening. This risk area includes: (i) the hiring or continued employment of individuals excluded from participation in the federal health care programs; or (ii) contracting with an individual or entity excluded from participation in the federal health care programs.
(e) Physician Sunshine Act. This risk area involves failing to report transfers of value to physicians, to the extent required to report such transfers by the Physician Sunshine Act.
(f) Marketing and Sales. This risk area involves marketing in a manner that is not honest, not straightforward, less than fully informative and/or deceptive. This risk area also involves salespeople offering physicians, podiatrists and other referral sources incentives, in cash or in kind, for their referrals or business.
4.3 Resources. The Compliance Officer will have the full resources of Anodyne available to him or her in preparing the annual risk assessment and annual compliance work plan. If responsibility for any particular aspect of the annual risk assessment is delegated by the Compliance Officer, the designated party or parties will prepare and submit reports documenting the results of the annual risk assessment to the Compliance Officer. The results of the risk assessment may be verified by internal or external audits, consultants, or such other means as the Compliance Officer determines to be necessary and appropriate.
4.4 Reporting. The Compliance Officer shall provide a report of the annual risk assessment and annual compliance work plan to the Manager. This report shall identify actual or potential areas of concern, a description of current measures taken, and recommendations to address areas of concern. At a minimum, for areas identified as high risk, the annual compliance work plan shall include review or development of applicable policies and procedures and internal controls, requirements for training and education, and plans for auditing and monitoring.
4.5 Training on New Risk Areas. Whenever the Compliance Officer identifies a new risk area, the Compliance Officer will evaluate whether it is necessary to develop and distribute new education and/or training materials, in accordance with Article 6.
AUDITING AND MONITORING
5.1 General. The Compliance Officer shall be responsible for ongoing monitoring and auditing. The Compliance Officer may utilize a variety of techniques to conduct monitoring, including periodic "spot checks." Monitoring and auditing activities may consist of on site visits, interviews (of current Employees or at an Employee's exit), review of written materials and documentation, trend analysis and questionnaires. Additionally, the Compliance Officer may arrange for periodic compliance audits by external auditors with expertise related to specific risk areas.
5.2 Annual Audit Plan. Audits and monitoring will generally reflect the areas of concern identified in the annual risk assessment. Based on the annual risk assessment, the Compliance Officer will develop an annual audit plan.
5.3 Periodic Audits. Periodic audits are designed to ensure ongoing claims processing accuracy and compliance with any new rule or regulation implemented since the most recent previous audit. Such audits shall also incorporate a review of whether the Compliance Materials have been adequately disseminated, whether appropriate training and educational programs have been conducted, whether appropriate records are being maintained, and whether disciplinary processes are working properly.
5.4 Response. The Compliance Officer will ensure that, in response to all audits, appropriate discipline plans or other corrective actions (e.g., adding new training and educational programs, or making changes to policies and procedures) are developed and fully implemented. If necessary, the Compliance Officer may arrange for a follow up audit or review of specific issues or practices to determine whether any recommended corrective actions have been implemented and have been successful. Any actions taken in response to an audit will be documented by the Compliance Officer or his or her designee.
5.5 Reporting. The Compliance Officer shall report regularly to the Manager regarding the implementation of the annual audit plan and the results of any other auditing and monitoring activities conducted during the prior year.
EDUCATION, TRAINING AND ATTESTATION
6.1 Policy. It is the policy of Anodyne to provide appropriate training to Employees to permit them to have sufficient familiarity with the Code of Conduct specifically, and the Compliance Plan generally, so that they are aware of their ethical and legal obligations and act responsibly. The Compliance Officer will track and record individual attendance at all required training and educational sessions and completion of the compliance attestation form. Failure to complete required training or sign a compliance attestation form may result in disciplinary action, including potential termination of an individual's relationship with Anodyne.
6.2 General Training. All Employees are required to undergo compliance training. Employees must undergo such training as part of their orientation, at which time they will receive a copy of the Code of Conduct. Thereafter, Employees will have general compliance training at least annually. Compliance training may occur in various formats, including web based and face to face training.
All general compliance training will be reviewed and updated annually. Specifically, the Compliance Officer will revise the compliance training program to address changes in external requirements (e.g., federal health care program requirements, OIG guidance, or other agency guidance) as well as internal activities (e.g., identified risk areas, results from audits, investigations, previous training and education program feedback, or trends in compliance reports).
6.3 Compliance Attestation Form. Upon orientation, or completion of annual compliance training, Employees are required to sign a compliance attestation form certifying that he or she: (a) has read the Code of Conduct; (b) will comply with the Code of Conduct, including the duty to report noncompliance with same; (c) has completed the requisite compliance training or education sessions regarding the Compliance Materials; (d) is not aware of any unreported noncompliance, violations, or any other issues or concerns related to compliance; and (e) understands that he or she may be subject to discipline for failure to abide by the Code of Conduct.
6.4 Specialized Training. In addition to general corporate compliance training, the Compliance Officer will work to identify and evaluate the need for specialized training, and to facilitate and document such training. When such training is provided, the Compliance Officer will annually evaluate the appropriateness of the training and make revisions to the training as necessary. The Compliance Officer will also track and record attendance at specialized training.
6.5 Communication of Changes to Code of Conduct. The Compliance Officer will distribute in writing and/or post in conspicuous places, any material modifications of, or amendments to, the Code of Conduct. The Compliance Officer will also communicate to affected parties any substantial changes to the Compliance Plan.
6.6 Other Compliance Communication Efforts. The Compliance Officers may, as necessary, provide periodic information about the Compliance Program as well as changes in applicable laws or ethical standards that may affect the responsibilities of Employees through written memoranda, newsletters, periodic training sessions or other appropriate forms of communication, including the posting of such information.
REPORTING, RESPONSE AND PREVENTION
7.1 Obligation to Report Suspected or Actual Noncompliance. In accordance with the Code of Conduct, all Employees are expected and required to report any suspected or actual noncompliance.
7.2 Anonymity. To the extent possible, all compliance related reports will be handled in a manner that protects the confidentiality of the reporting individual if he or she so requests. However, there may be circumstances in which confidentiality cannot be maintained. Some examples of this include situations where the problem is known only to very few people or situations in which the government or another payor or funding source is involved. In such cases, Anodyne may be required to provide the name of the individual who first brought the problem to the attention of the organization.
7.3 Nonretaliation Policy. It is the policy of Anodyne to ensure that individuals who make a report in good faith do not suffer any retaliation for doing so. The Compliance Officer will explain Anodyne's nonretaliation policy to each caller or reporter and give the reporter a means for contacting them confidentially to report any actions the reporter believes are retaliatory. The Compliance Officer will ensure that any report of retaliation is appropriately investigated.
7.4 Reporting Mechanisms. Employees or Outside Parties may report compliance concerns directly to the Compliance Officer in a face-to-face meeting, via telephone, through the use of voicemail or via e-mail. Employees or Outside Parties may also write a confidential letter to the Compliance Officer.
7.5 Investigation. Upon receiving a report of actual or suspected noncompliance, the Compliance Officer will initiate prompt steps to ensure the conduct in question is investigated (including, as appropriate, involving outside legal counsel) to determine whether noncompliance has occurred. Investigations may involve, without limitation: (a) interviewing individuals with potential knowledge of the matter; and/or (b) conducting a review of relevant documents.
7.6 Response. In the event the investigation identifies actual or suspected noncompliance, Anodyne may undertake one or more of the following actions, as appropriate:
(a) Immediately ceasing any actual noncompliance;
(b) Consulting with legal counsel to determine whether voluntary reporting of the actual or suspected noncompliance to the appropriate governmental authority is warranted;
(c) Making any legally required repayment;
(d) Initiating disciplinary action, as appropriate;
(e) Promptly undertaking appropriate training and education to prevent a recurrence of the actual or suspected noncompliance;
(f) Conducting a review of the Compliance Materials and/or applicable policies and procedures to determine whether revisions of the current Compliance Materials and/or applicable policies or procedures, or the development of new policies and/or procedures, are needed to minimize future risk of actual or suspected noncompliance; and/or
(g) Conducting, as appropriate, follow up monitoring or auditing to ensure effective resolution of the actual or suspected noncompliance.
ENFORCEMENT AND DISCIPLINE
8.1 Enforcement of Compliance Plan and Code of Conduct. Adherence to the Compliance Program, Compliance Materials, and Anodyne policies and procedures is central to the duties of every Employee. Anodyne will take prompt action to address noncompliance with the Compliance Program, Compliance Materials, Anodyne policies and procedures, or applicable laws or regulations, or the failure to appropriately report noncompliance. Such action may include counseling or additional training and education, but also may include disciplinary action, up to and including termination of employment, the applicable business relationship or contract, or affiliation (as described in Section 8.3). The following are examples of conduct that may result in disciplinary action:
(a) The failure to perform any required obligation relating to compliance with the Compliance Program or the Compliance Materials;
(b) The failure to report suspected violations of the Compliance Program, the Compliance Materials, Anodyne policies or procedures, or applicable laws and regulations; or
(c) Retaliating or attempting to retaliate against another person who reported a suspected violation.
8.2 Reporting Violation of Laws. Anodyne shall report compliance violations to the appropriate governmental authority when required to do so. The Compliance Officer shall develop a process to ensure that such reports are made timely.
8.3 Compliance as an Element of Job Performance. Employees (including the Manager and the Compliance Officer) will be subject to discipline, in accordance with applicable policies, for failing to comply with the Compliance Program, the Code of Conduct, Anodyne policies or procedures, or applicable laws and regulations. Discipline may include reprimand, suspension, termination or severance of their relationship with Anodyne. Adherence to, and support of, the Code of Conduct will be considered in decisions regarding hiring, promotion, performance review and compensation for all Employees, as well as for prospective Employees.
REVIEW AND APPROVAL OF COMPLIANCE MATERIALS
9.1 Code of Conduct. At least annually, the Compliance Officer shall review the Code of Conduct and revise it as necessary due to changing laws and regulations or Anodyne's operations. The Manager must approve any revisions to the Code of Conduct. If substantive revisions to the Code of Conduct are made, the new Code of Conduct will be distributed to all Employees and Outside Parties as soon as practicable.
9.2 Compliance Plan. The Compliance Officer shall review the contents of the Compliance Plan annually and revise it as necessary due to changing laws and regulations or Anodyne's operations. The Manager must approve any revisions to the Compliance Plan. While Anodyne will generally attempt to communicate revisions prior to implementation, Anodyne may change the Compliance Plan without providing prior notice to affected parties. The Compliance Officer shall ensure that material changes to the Compliance Plan are communicated to all affected parties as soon as possible after the change.
The Compliance Plan has been prepared to outline the broad principles of legal and ethical business conduct embraced by Anodyne. It is not a complete list of legal or ethical questions you might face in the course of business. Therefore, this plan must be used together with your common sense and good judgment.
If you are in doubt or have a specific question, you should contact the Compliance Officer.
CODE OF CONDUCT
Anodyne, LLC ("Anodyne") is dedicated and committed to meeting high ethical standards and complying with all applicable laws in all activities regarding the provision of diabetic shoes and/or inserts. To ensure Anodyne achieves this operating goal, it has established a Corporate Compliance Program, as outlined in a Compliance Plan ("Compliance Plan"), designed to create and foster an organizational culture encouraging open communication regarding compliance issues, without fear of retaliation, which is embraced by every Anodyne employee and/or vendor who furnishes services or provides items to Anodyne (in this Code of Conduct, each such person is referred to as "you" or "your").
In addition to Anodyne's general policies and procedures and the Employee Handbook, this Code of Conduct summarizes the standards of behavior expected of you. To the extent that all individuals associated with Anodyne act responsibly, Anodyne's reputation as an ethical and lawful organization will be protected. Acting responsibly means that, at all times, you will: (1) perform your duties in a manner that upholds and complies with the principles set forth in this Code of Conduct, the Compliance Plan and all Anodyne policies, procedures, guidelines and instructions; (2) ensure your conduct meets the requirements of all relevant federal, state, and local laws and regulations; (3) take responsibility for your behavior (including both acts and omissions); and (4) immediately report anything that you believe to be inconsistent with the principles of this Code of Conduct. You will be notified of any material changes to this Code of Conduct.
No set of policies can substitute for good judgment and common sense, nor can a single set of policies cover every difficult circumstance that arises. The complexity of the health care environment can sometimes make it difficult to recognize behavior or practices that may be illegal or improper. At Anodyne, maintaining a culture of compliance means, in part, that if you have a question about something, if you are uncertain as to what the right course of conduct is in any situation, or you observe any potential compliance issue, you are obligated to report this to Anodyne's Compliance Officer ("Compliance Officer"). It is the policy of Anodyne that no person will suffer any adverse effect on his or her job or career advancement as a result of raising an ethical or legal concern in good faith.
Compliance with this Code of Conduct is a condition of employment and a prerequisite for affiliation or doing business with Anodyne. Violations of this Code of Conduct will be grounds for discipline, up to and including immediate termination of your employment or affiliation with Anodyne. Consistent with its policies, Anodyne shall not engage in or permit any action of retaliation or reprisal to be taken against an employee who, in good faith, reports suspected and/or actual misconduct.
PRINCIPLE 1. Legal and Ethical Conduct. You are required, as a condition of your employment or affiliation with Anodyne, to comply with all applicable laws and regulations, standards and other requirements imposed on our business by any level of government or certifying agency. Without limiting the generality of that statement, you must follow and satisfy all requirements of the federal and state laws and regulations. In particular, you shall ensure that you do not make any statements or create any documentation that is false, fraudulent, inaccurate or fictitious in connection with Anodyne. Anodyne will not tolerate any falsification of any records. Similarly, Anodyne will not pursue any business opportunity that requires engaging in unethical or illegal activity.
Anodyne and its personnel shall engage in fair, honest, respectful, dignified and ethical relationships among and outside Anodyne. You must be honest in doing your job or fulfilling your duties, and maintain the highest ethical professional standards, judgment and objectivity. In particular, Anodyne seeks positive relationships with health care providers and government programs. Positive relationships require ongoing communication. In very practical terms, this means you must perform you duties in a way that promotes the public's trust in Anodyne—and you.
Your integrity is paramount, and it is everyone's collective responsibility to maintain Anodyne's institutional integrity and reputation. You must be honest and forthright in any representations made to health care providers, vendors, contractors, other employees or agents, and the community. You shall not use or reveal, for any personal or financial gain, any proprietary or confidential information concerning Anodyne.
PRINCIPLE 2: Conflicts of Interest. You should avoid situations that could result in a conflict of interest. You shall not have other jobs that interfere with your ability to perform your duties at Anodyne. Just as importantly, you must avoid any activity that conflicts with the interests of Anodyne, or that even creates the appearance of impropriety. In particular, promoting business with any entity with which you have a familial or other personal or business relationship may constitute a conflict of interest. You must make a disclosure in advance to the Compliance Officer and obtain written approval from the Manager prior to proceeding with the transaction. If you suspect that a conflict may exist or be created, then you should consult with or notify the Compliance Officer. Similarly, any issue you observe with respect to vendors and contractors shall immediately be reported to the Compliance Officer.
PRINCIPLE 3: Workplace Environment. Work rules were created to protect us all. Anodyne's personnel are expected to comply with Anodyne's rules and to immediately report violations of these policies to a supervisor or the Compliance Officer. In addition, all persons associated with Anodyne must respect each other as human beings. Anodyne's personnel shall show proper respect and consideration for each other, regardless of position or station. Discriminatory treatment, harassment, abuse or intimidation will not be tolerated. Anodyne is a drug free workplace in accordance with its policies. If you experience significant differences in professional judgment with another person, you should talk to a member of the management team and/or the Compliance Officer to resolve it.