|
| About UMD - Code of Conduct |
|
Trust is an intangible corporate asset. There is no “trust” column in our balance sheet. We do not list it in our reports. Yet it is as relevant to our success as premiums. It enables the loyalty of our customers and stakeholders. As employees we have a responsibility to build high levels of trust with customers, suppliers, stakeholders, regulators and each other. The principles and guidelines that follow, including the laws, policies and practices on which they are based, are designed to build that trust with every stakeholder. The goal for each of us is to maintain the highest standards of integrity, honesty and ethical behavior.
This Code of Conduct and Compliance Program (the “Code”) represents the policy of HealthNow Systems, Inc. and HealthNow New York Inc. (hereafter referred to as the “Company”). The Code applies to all Board Members, officers and employees of all divisions and subsidiaries of the Company and was prepared to provide employees, and those with whom the Company does business, with a formal statement of the Company’s commitment to the standards and rules of ethical conduct.
Contracting with the government requires that we pay particular attention to the special rules of behavior that the government imposes on us. As a Medicare contractor, we have special compliance rules under the contracts or under the Corporate Compliance Agreement attached to the contract with the Centers for Medicare and Medicaid Services ("CMS"). It is essential that all employees who have obligations under one of the Company's government programs, such as our Medicare contracts, Medicare Advantage, Medicare Part D Prescription Drug Benefit, Medicaid products, or the Federal Employee Health Benefits ("FEP") program be aware of and follow the special rules described in the section of this Code titled "Interacting with Government." In addition, employees with responsibility for the Company's Part D program are subject to and shall comply with Company's Medicare Prescription Drug Benefit (Part D) Fraud, Waste and Abuse Compliance Plan (Part D Compliance Plan). |
|
