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Upstate Medicare Division
UMD's main office is located in Binghamton, NY.
UMD's main office is located in Binghamton, NY
About UMD
Mission, Vision, Values Mission, Vision, Values
Code of Conduct:
Code of Conduct - Letter from President & CEO A Letter from the President & CEO
Code of Conduct - Message from Compliance Officer A Message from the Compliance Officer
Code of Conduct - Introduction Introduction
Code of Conduct - Responsibility to Ourselves and Our Community Responsibility to Ourselves and Our Community
Code of Conduct - Protecting Stakeholder Value Protecting Stakeholder Value
Code of Conduct - Operating with Integrity Operating with Integrity
Code of Conduct - Interacting with Government Interacting with Government
Code of Conduct - The Compliance Program The Compliance Program
Code of Conduct - Compliance Program Monitoring Responsibilities Compliance Program Monitoring Responsibilities
Code of Conduct - Important Contacts Important Contacts
Code of Conduct - Employee Acknowledgement Employee Acknow-ledgement
 

About UMD - Code of Conduct
Responsibility to Ourselves and Our Community

Respecting One Another
To paraphrase an old adage, trust begins at home. The way we treat each other and our work environment affects the way we do our jobs. When we work in an atmosphere of trust and respect, we can create more productive relationships with our co-workers, members, beneficiaries, providers, subscribers, suppliers and stakeholders. Our responsibility to ourselves and our environment begins with the basic tenets of respect and honesty, and builds on our mutual commitment to open communication and teamwork.

Our Basic Responsibilities
As employees, we have responsibility for upholding the values, principles and standards we share as members of the Company team.
  • Be respectful, cooperative and helpful toward members, beneficiaries, providers, subscribers, co-workers, suppliers and the general public.


  • Do not steal from, nor act in an abusive, threatening, discriminatory, harassing or obscene manner toward any employee, member, beneficiary, provider or supplier.


  • Respect the authority/responsibility of our managers and other Company managers.


  • Do not disparage the Company or any Company employee.


  • Do not misrepresent the Company, its products, or its people. We are truthful in all that we do.


  • Follow all Company policies governing day-to-day performance of our jobs, including, but not limited to, the standards set forth in this Code.


  • Do not engage in improper or illegal behavior even if directed to do so by someone in higher authority. No one, regardless of position, has the authority to direct us to commit a wrongful act.


  • Cooperate fully when the Company is investigating work-related matters.
Open Communication
Open and honest communication fosters teamwork and creativity. It builds trust with members, beneficiaries, providers, subscribers, customers, regulators, stakeholders and each other.

The Company is committed to providing an environment that encourages and fosters open internal communication. This means that the Company and its managers will encourage and provide the means for employees to express their ideas, opinions, attitudes and concerns to management without fear of reprisal. The Company and all its employees will value and respect what members and providers have to say and remain receptive and open toward customers and their ideas and opinions. The Company will provide employees and all other stakeholders with accurate and timely information of importance to them and the Company.

Employee Privacy
The Company often needs to acquire and retain personal information on individual employees for effective operation of the Company. The Company limits access to such information to authorized personnel who need the information for business or legal purposes.

The Company may monitor the personal communications of employees at work and search their work spaces. Thus, employees should not assume that these communications and work spaces are private. The Company retains the right to search any and all Company property and property brought onto Company premises at anytime, including but not limited to offices, desks, cabinets, e-mail, voice mail and computer files as well as employees’ possessions brought into the workplace.

The Company will comply with all applicable laws and legal processes regarding disclosure and forfeiture of personal information, confiscated illegal substances or material evidence. Wherever applicable law does not regulate the release of these items, we will protect these items from unreasonable disclosure.
Question: If an employee is terminated from the company and his or her potential employer calls for a reference, does our company give information on job performance, attendance or compensation to the potential employer?

Answer: No. Regardless of whether an employee is terminated or resigns, human resource policy does not allow for the disclosure of the contents of his or her personnel file. The only information given is a verfication that the person worked at the Company, positions held and dates of employment. Salary information will be released only with the written consent of the terminated employee.
Non-Discrimination and Equal Employment Opportunity
The Company is an equal opportunity employer. It is our policy that applicants for employment and employees receive fair and equal treatment. The Company prohibits all forms of unlawful discrimination including discrimination on account of race, color, religion, sex, national origin or citizenship, age, marital status, sexual orientation, genetic carrier status or predisposition, disability or status as a special disabled veteran, veteran of the Vietnam-era, or any other veteran who served on active duty during a war or in a campaign or expedition for which campaign badge has been authorized, recently separated veterans, or other protected veterans.

The Company and its employees are committed to establishing and maintaining a workplace free of unlawful discrimination. We strive to evaluate all employees solely based on merit. We are fully committed to equal employment opportunity for all employees, and applicants for employment, by ensuring that there is no unlawful discrimination in recruitment, hiring, termination, promotions, salary treatment, or any other condition of employment or career development. We will treat employees, customers, suppliers, and all with whom we come in contact, with respect and dignity. We will not tolerate the use of discriminatory slurs or any other remarks, jokes or conduct that in the judgment of the Company encourages or permits an offensive or hostile work environment.
Question: One of my co-workers has a habit of telling questionable ethnic or “off-color” jokes. This offends me. How can I get this to stop?

Answer: Company policy prohibits this type of behavior. You have the option of discussing your feelings with the person telling the jokes, if you prefer, or if you cannot resolve the matter in this way, you should discuss the situation with your manager, or you may contact a representative from the Human Resources Department, or you may contact a member of the Compliance staff.
Harassment
The Company prohibits all forms of unlawful harassment, in accordance with the Company’s corporate policy. Unlawful harassment includes harassment of employees by employees and harassment of employees by non-employees whom Company employees interact with during work. Non-employees include employees of contractors, customers, vendors, suppliers and temporary employment agencies. Similarly, Company employees are prohibited from engaging in unlawful harassment of non-employees with whom they interact, including employees of contractors, customers, suppliers, and temporary employment agencies.

Generally, unlawful harassment is defined as verbal or physical conduct which denigrates or shows hostility or aversion to an individual because of his or her race, religion, color, gender, age, national original or citizenship, marital status, veteran status, disability, sexual orientation, or genetic carrier status or predisposition, or that of his or her relatives, friends or associates, and which:
  1. Has the purpose or effect of creating an intimidating, hostile, or offensive work environment; or


  2. Has the purpose or effect of unreasonably interfering with an individual’s work performance; or


  3. Otherwise adversely affects an individual’s employment opportunities.
For example, the following kinds of behavior, or others with a similar harassing effect, are absolutely prohibited:
  1. Abusing an employee through epithets, slurs, negative stereotyping, or threatening, intimidating or hostile acts (even if claimed to be “jokes” or “pranks”) which relate to race, religion, color, gender, age, national origin or citizenship, marital status, veteran status, disability, sexual orientation, genetic carrier status or predisposition; and


  2. Written or graphic material which denigrates or shows hostility or aversion toward an individual or group because of race, religion, color, gender, age, national origin or citizenship, marital status, veteran status, disability, sexual orientation, or genetic carrier status or predisposition, and is displayed or circulated in the workplace.
Company policy also strictly prohibits any form of sexual harassment in the workplace. Sexual harassment may include, but is not limited to:
  • Stating or threatening, either explicitly or implicitly, that an individual’s submission to, or rejection of, sexual advances will in any way influence any decision regarding that individual’s term or conditions of employment or other business relationship.


  • Existence of a sexually abusive or hostile working environment. This is characterized by unwelcome sexual advances, verbal or physical conduct of a sexual nature, gender harassment (even if the conduct is not sexual in nature), or display of sexually suggestive objects or pictures.
Family and Other Personal Relationships
All of our personnel decisions must be based on sound management practices. We cannot allow personal relationships to bias our objectivity. To provide a working environment free from improper influence, we must reasonably separate considerations of family or personal relationships from matters relating to supervision, job assignment, appraisals, promotions, compensation decisions and hiring practices.

The Company requires employees to immediately disclose to their managers any family or other personal relationships that may cause, or give the appearance of, a conflict of interest either internally or with competitors or suppliers.

Outside Employment and Other Activities
Employees must not engage in activities that conflict with, have a negative impact on or are otherwise incompatible with, our responsibilities to the Company.

As the health insurance industry becomes broader and more complex and the Company enters new markets, we must take special care to avoid outside activities that conflict or appear to conflict with the Company’s business. Employees are not permitted to have outside employment with any company engaged in a line of business in which our Company is currently operating, or which it is actively seeking to enter.

Employees should not engage in any activity that aids a competitor of the Company. Such activities include any outside work by an employee (including self-employment) that involve the planning, design, sale or purchase of services or products that the Company currently provides or plans to provide. The only time employees may provide assistance to others who may be competitors is when they are authorized to do so under specific Company projects such as joint-venture activities, in accordance with applicable laws, regulations and Company policy.

If employees have an affiliation or interest in any outside organization or governmental body, they should notify their managers and disqualify themselves from making any decisions on behalf of the organization or governmental body that specifically involve the Company - for example, a procurement or permit decision - to avoid any conflict of interest or appearance of a conflict of interest that could damage the Company’s reputation.

Each year, the Board of Directors, officers, salaried, management and other employees are asked to sign a Conflict of Interest Disclosure Statement, disclosing any personal, business or financial interests or activities that may conflict or appear to conflict with the interests of the Company. All actual or potential conflicts must be disclosed so that the Company can determine whether a conflict exists and if so, what actions should be taken to eliminate or avoid the conflict. Persons to whom the Conflict of Interest Disclosure Statement is distributed must answer all questions fully and accurately and must attest to the accuracy of the information given.

Safety in the Workplace
The Company is committed to providing a safe and secure work environment. Accordingly, it is Company policy to comply with all safety and health-related statutes and regulations, as well as Company policies regarding employees safety and health. Standards for workplace safety include:

Weapons: Our commitment to safety means that employees must not carry or possess firearms, knives, defense sprays, explosives, or any other weapons on Company-leased or -owned premises, in Company vehicles or anywhere else during working hours. This applies even to employees who have a permit or license to carry a weapon.

Workplace Violence: The Company strictly prohibits acts of physical intimidation, assaults, or threats of violence by employees. Violations of this policy are not tolerated and must be referred immediately to your manager, another manager or directly to Building Security or the Human Resources Department.

Alcohol: The consumption of alcohol in any situation that might reflect adversely on the Company, endanger ourselves or others, or impair our ability to perform our duties is strictly prohibited. No one may report to work or remain at work if, in the judgment of his or her manager, his or her performance is impaired because he or she is under the influence of alcohol. Alcohol must never be consumed in Company vehicles, nor should any employee consume alcohol in personal motor vehicles while in use for Company business. Any suspected violation of this policy should be promptly reported to your manager or the Human Resources Department.

From time to time, certain employees participate in business-related activities involving employer groups, vendors, providers, brokers and other customers that occur outside of the normal work environment. These activities are generally considered reasonable and natural extensions of our business relationships. Examples include attendance at sporting events, golf outings, fund raisers and other community activities. In some of these situations, alcohol may be served. It is critical that employees conduct themselves responsibly and not consume amounts that would be considered over legal limits. Further, employees should display professionalism and not conduct themselves in a manner that discredits the Company. If the employee is entertaining a current or prospective business associate, sound judgment should be exercised with regard to the place for the entertainment and the amount of alcohol purchased and/or consumed. The Company does not condone the purchase or consumption of excessive amounts of alcohol by any employee when they are representing the Company. Employees must not put themselves or our business associates in situations that could negatively impact their health and well-being and expose the Company to any potential liability.

Drugs: The Company strictly prohibits the sale, use, possession, manufacture and distribution of illegal drugs on Company property, in company vehicles or on company time. The Company also prohibits the abuse of any legal drugs while on Company time or business or on Company premises. No one may report to work or remain at work if he or she is under the influence of illegal drugs. Any suspected violation of this policy should be promptly reported to your manager or the Human Resources Department.

Smoking: The Company prohibits smoking in all areas of the buildings and grounds (except in designated areas). Employees who become aware of violations should promptly report them to their manager or to Security.

Safe Work Practices: The Company has developed many practices in an effort to protect employees from accidental injuries. Employees who become aware of potentially harmful or dangerous conditions at work or on company property must promptly report them to their management or the Human Resources Department.
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This page updated
November 16, 2006



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