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| About UMD - Code of Conduct |
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Introduction
The Company is committed to conducting its business with integrity and in accordance with all federal, state and local laws to which its business activities are subject. It is the longstanding policy of the Company to prevent the occurrence of unethical or unlawful behavior; to halt such behavior as soon as reasonably possible after its discovery; to discipline personnel who violate the Company's policies including individuals responsible for the failure to report a suspected violation; and to implement any changes in policy and procedure necessary to prevent any recurrence of a violation. The Company has adopted the Code of Conduct and other related Compliance Program elements and policies including the Part D Compliance Plan to reflect these commitments (the "Compliance Program").
The purpose of the Compliance Program is twofold. First, it provides a mechanism to enforce the Company’s Code of Conduct. Second, and perhaps the most important, the Compliance Program, coupled with the Code of Conduct and Company policies, sets an ethical standard for conducting business and creates a corporate culture that enhances the reputation of the Company.
Responsible corporations realize that prudence, economics, and common sense dictate the enactment of a Compliance Program. A Compliance Program is a mechanism created by an entity to educate its personnel, sensitize them to ethical and criminal misconduct, monitor for compliance with such expectations, audit for and investigate wrongdoing, and sanction violators.
The hallmark of an effective Compliance Program is “due diligence.” It is a program designed to promote due diligence in everything from the hiring of employees to the auditing of records. It is a mechanism to ensure that an entity diligently strives to prevent and detect misconduct and criminal activity. The commitment of the Company through a combined Code of Conduct and Compliance Program is to encourage ethical conduct and a corporate culture to achieve this due diligence standard.
The Compliance Program includes education, training, detection, investigation, reporting and methods to take action. The Compliance Program also requires that agents acting for or on behalf of the Company also enact and/or comply with the Company’s Compliance Program.
The Company utilizes a variety of tools to implement the Compliance Program such as education, employee performance evaluations, a confidential disclosure process and internal and external audits. The Company monitors this program to verify compliance with its published standards.
The Company requires all personnel to internally report all potential non-compliance with the Code of Conduct Compliance Program. The confidential disclosure process provides a variety of means to report such non-compliance. No individual’s position or influence is considered to be more important than the goal of institutional integrity. Those who make a good faith report of suspected wrongdoing will be protected from retaliation. |
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