Business Conduct & Compliance
InnovaCor's™ commitment to compliance, ethics and excellence in business conduct is fundamental to achieving its mission of Optimizing Care, Reducing Cost and Eliminating Waste. All employees agree and undergo annual training to assure adherence to a comprehensive and rigorous set of business practices.
Our Standards of Business Conduct reinforce Innovacor's™ commitment to abide by all applicable laws and regulations, and provide employees guidance in identifying and handling a variety of potentially challenging compliance issues and concerns. Remember, these Standards cannot anticipate every situation that employees may face. However, no concern is too small or unimportant if it implicates InnovaCor’s™ conduct in the market. InnovaCor™ expects employees to maintain the highest standards of loyalty and ethical principles in all business activities in order to promote confidence in the services provided to members.
Policies and Procedures
We have adopted corporate policies and procedures addressing many issues covered by these Standards. It is the responsibility of every InnovaCor™ employee to review and understand the policies and procedures. Failure to comply with these Standards or the policies and procedures may result in disciplinary action.
Ethical Business Conduct
All employees are expected to act ethically and with integrity, and to uphold these values when performing their jobs. InnovaCor’s™ members, suppliers and the government expect and deserve the utmost in fair dealing. InnovaCor’s™ commitment to ethics and integrity in business includes a high level of transparency in all business activities.
Comply With All Laws and Regulatory Requirements
All InnovaCor employees are expected to comply with all applicable federal, state and local laws and regulations. In addition to potential civil and criminal penalties against individual employees and the company, violations of law can compromise InnovaCor’s™ reputation and ability to conduct business. Increased governmental scrutiny and regulation in the health care and group purchasing industries requires diligence to ensure that all transactions are within applicable laws and regulations.
Conflict of Interest
The purpose of this policy is to preserve and protect the integrity and independence of all decisions affecting InnovaCor™ made by its officers and employees so that the interests of InnovaCor™, and not that of any individual, prevail. The appearance of a conflict or a breach of confidence can often be as serious as an actual conflict or breach, and can result in irreparable damage to InnovaCor™ and its reputation. At the same time, InnovaCor™ does not wish to unnecessarily infringe upon the personal lives of its employees. Each individual has a responsibility and will be held accountable for complying with the spirit and letter of this policy, and when necessary, to seek assistance from management, the Compliance Office.
External Conflicts of Interests
Employees with responsibilities for external relationships must avoid situations that could cause an actual or perceived conflict of interest or make it difficult to carry out job responsibilities or act in the best interest of InnovaCor™. When an employee’s responsibilities include working with members, suppliers or competitors, care should be taken to ensure that business decisions are free from any actual or perceived conflict of interest.
Internal Conflicts of Interest
It is InnovaCor’s™ policy that employees who have personal or family relationships with another InnovaCor™ employee, member or supplier that impede or have the appearance of impeding objective business decisions, will not be assigned to positions which may create such a conflict of interest. If confronted with a potential conflict, employees should speak to their supervisor or a member of the Compliance Office.
InnovaCor™ encourages employees as private citizens to participate during non-business hours in the electoral process and in making contributions to political causes of their choice. Federal law prohibits a corporation from making direct or indirect political contributions of any kind, including transportation or other services at company expense.
Employees are prohibited from giving, offering, accepting or soliciting anything that could be construed as a bribe, kickback or other illegal or unethical payment in connection with InnovaCor™ or its business. Employees who receive or become aware of such offers, solicitations or payments must report them immediately to their supervisor and to InnovaCor’s™ Compliance Office.
All financial reporting and accounting will be maintained and reported in accordance with InnovaCor’s™ internal policies and procedures. InnovaCor™ will comply with generally accepted accounting principles designed to ensure that financial reports accurately describe InnovaCor’s™ true financial position. In addition, where appropriate, InnovaCor™ will provide accurate and timely financial reporting to its members.
Business Meals and Entertainment
Business meals and entertainment can constitute inappropriate inducements that violate InnovaCor™ policies and applicable laws and regulations. Employees will use their best judgment regarding participation in recreational or social outings, and any other type of business entertainment, and must avoid even the appearance of impropriety. In accordance with the Policies and Procedures, employees may provide or receive reasonable meals and business entertainment that are not given to influence contracting or other business decision-making.
InnovaCor™ generally prohibits employees from giving or receiving gifts from members or suppliers. In accordance with our policies and procedures, employees may give or receive gifts of minimal value that are not given to influence contracting or other business decision-making. Employees may not use their own money to provide gifts.
Trade secrets and other types of intellectual property provide InnovaCor™ with a competitive advantage. Technical knowledge, know-how, trademarks, service marks, company names, supplier lists, member lists, copyrights and other trade secrets are valuable assets. Their protection is essential for InnovaCor’s™ continued business success. If an employee becomes aware of any party who may be misusing any of InnovaCor’s™ intellectual property, that misuse should be immediately brought to the attention of the employee’s supervisor and the InnovaCor™ Legal Office.
Employees are also expected to respect the intellectual property of others, and refrain from infringing valid patents, trademarks, service marks, copyrights or other intellectual property not owned by or licensed to InnovaCor™. Copying books, articles or software, or downloading and distributing or reproducing copyrighted information from the Internet may violate copyright laws and result in sanctions against the employee and InnovaCor™. Contracts or other arrangements relating to the use of intellectual property rights (patents, trademarks, service marks, designs, copyrights, know-how and trade secrets) are often subject to special legal rules. All such contracts or other arrangements must be reviewed and approved by the InnovaCor™ Legal Office.
In the course of employment with InnovaCor™, employees will come into possession of and have access to confidential and proprietary documents of InnovaCor™, its members and suppliers. Except as required by law or as directed by InnovaCor™, an employee must not divulge such confidential or proprietary information to any third party.
Record-Keeping and Document Retention
InnovaCor™ has policies and procedures relating to the creation, maintenance, retention and destruction of corporate documents, including but not limited to supplier contracts, correspondence and bid materials. All InnovaCor™ employees are required to adhere to such record-keeping and document retention policies.
Travel and Business-Related Expenses
Employees are required to promptly record business expenses completely and accurately in accordance with InnovaCor's™ policies and procedures. Entertainment, meals and travel expenses that are reported on expense reports must have a legitimate business purpose and not be lavish or extravagant.