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At MedTrust, high standards of professional conduct and ethics are essential for us to achieve our goals. We rely on the good judgment of our employees, associates, and agents to comply with the law, act with integrity, and safeguard the company’s reputation in every situation. Our Code of Conduct clearly defines our basic expectations of employees and all those with whom we do business. This Code is attached below for your reference.
If you have any questions regarding MedTrust's Code of Conduct, please call our corporate headquarters at 210-496-2323 and ask for the Compliance Officer.
Medtrust is fully committed to maintaining a high degree of integrity, ethics and compliance, conducting every business transaction in compliance with the spirit and letter of the law and MedTrust policies. Strict adherence to the Code of Conduct will help to ensure that MedTrust and its employees prosper and maintina this objective of doing business with integrity.
The Code of Conduct provides an introduction to important laws and policies that must be followed. The Code of Conduct may not seem entirely new. Indeed, the Code of Conduct memorializes, organizes and summarizes various practices that have been ongoing at MedTrust.
The Code of Conduct is designed to help each of us:
· Understand and follow the basic ethics and compliance rules that apply to our jobs
· Know when and where to ask for advice
Who Must Follow This Code of Conduct?
This Code of Conduct applies to all MedTrust employees, including officers, regardless of the contractual basis of their employment. No one has the authority to direct or authorize anyone to violate any law or engage in unethical conduct. This Code of Conduct may also apply to independent third parties hired by or working with MedTrust.
Your Personal Pledge to Do the Right Thing
This Code of Conduct represents a commitment by MedTrust to do business with integrity. By working with MedTrust, you are agreeing to uphold this commitment. Understanding this Code of Conduct and the company policies that apply to you is an essential function of your job. Employees who fail to follow these standards put themselves, their co-workers, and MedTrust at risk. Such employees are also subject to disciplinary action up to and including termination of employment.
What About Those Who Supervise Others?
Supervisors and managers have an affirmative duty under this Code of Conduct to:
· Set an example – showing what it means to act with integrity
· Ensure that those they supervise have adequate knowledge and resources to follow the Code of Conduct’s standards
· Consult with MedTrust ethics and compliance advisers to obtain clarity or support on ethics and compliance issues
· Monitor compliance of the people they supervise
· Enforce the standards of the Code of Conduct and all other related company standards
· Support employees who in good faith raise questions or concerns about compliance and integrity
· Never retaliate or permit retaliation
· Report instances of noncompliance to the proper management level
Does This Code of Conduct Explain All the Standards I need to Know?
This Code of Conduct is the cornerstone of MedTrust’s commitment to integrity. However, this Code of Conduct is not intended to describe every law or policy that may apply to you. Make sure you know the additional rules that apply to you. To learn more about the other laws, regulations, standards and policies that may apply to you, consult the terms of contract applicable to your work, or speak with your manager or his/her superior or the Compliance Officer.
Your Duty to Speak Up
See something? Hear something? Say something!
MedTrust strives to create a culture based on trust and individual responsibility. Employees may, however, encounter unethical or illegal behavior while at work. MedTrust is committed to providing a comfortable environment for employees to report such behavior. Each employee has the responsibility to speak up if something does not seem right.
Confidentiality will be maintained to the extent consistent with the best interest of the employees involved, the company and the company’s obligations to act ethically and responsibly.
Your supervisor is typically the best place to start with a compliance or integrity issue. However, you may also seek advice or report concerns to any manager of MedTrust or the Compliance Officer.
If a violation of this Code is found, the Company will take appropriate disciplinary action, up to and including termination. In addition, the Company may pursue any and all legal remedies available to it, including legal action.
The Compliance Officer at MedTrust administers the compliance program and is accessible by calling the company headquarters in San Antonio. Or to report a concern you may access the employee hotline at 1-877-582-8167. If you have any questions or concerns regarding any area of the Code of Conduct reach out to the Compliance Officer for guidance or clarification.
Anti-retaliation
MedTrust prohibits retaliation, or taking any action with the intent to retaliate, against any employee who makes a report in good faith of a potential violation of the Code of Conduct or participates in an investigation of any such reports. No employee making such a report in good faith will be discriminated against in terms and conditions of employment as a result of having made a report. Retaliation or a threat of retaliation is a serious violation of this Code of Conduct that will result in appropriate disciplinary action, up to and including termination of employment of anyone who retaliated against an employee.
Conducting Business
MedTrust is fully committed to maintaining a high degree of integrity, ethics and compliance, conducting every business transaction in compliance with the spirit and letter of the law and MedTrust policies. High standards of professional conduct and ethics are essential for MedTrust to achieve its goals. We rely on the good judgment of our employees to comply with the law, act with integrity and safeguard the company’s reputation in every situation. Our culture is based on trust, mutual respect and high standards of professional conduct and ethics. This Code of Conduct makes clear our basic expectations of our employees and all those with whom we do business.
Conflicts of Interest
MedTrust depends on the continued trust of our clients, subcontractors and other stakeholders. Conflicts of interest, or the appearance of such conflicts, undermine the trust in MedTrust’s good name. A conflict of interest arises in any situation in which a MedTrust employee’s personal, social, financial or political activities have the potential of interfering with his or her objectivity or work at MedTrust. MedTrust employees must avoid any situation that would create a conflict, or even the appearance of conflict, between their private interests and the interests of MedTrust.
Conflicts of interest can take many forms; the Code of Conduct addresses several of them. It is the responsibility of each employee to prevent conflicts of interest or the appearance of one by seeking advice when there may be a conflict. It is also each employee’s responsibility to disclose all situations that might present a real or perceived conflict of interest. Any employee that becomes aware of any transactions or relationships that may give rise to a conflict of interest must disclose the transaction or relationship. An employee’s direct supervisor or the Compliance Officer are the appropriate resources for assessing potential conflicts of interest.
Disclosure of a conflict may not resolve the conflict. Once a conflict is disclosed, the supervisor or Compliance Officer will work with the employee to address the risks associated with the conflict. This process may include termination of the arrangements that created the conflict.
Employees must disclose any of these circumstances that involve themselves or their family members:
· An employee’s position at MedTrust involves dealing with a family member as a competitor, vendor, or client of MedTrust
· Employment at MedTrust and at any other place at the same time if the employment negatively impacts the time or attention that must be devoted to MedTrust’s affairs
· Employment by MedTrust and by anyone else at the same time that is a present or potential competitor, vendor, or client of MedTrust
· Holding of any substantial financial interest in any competitor, vendor, or client of MedTrust. “Substantial” means an interest valued at more than 50% of your annual MedTrust salary. The term “financial interest” refers to any form of ownership or partial ownership, but does not include interests in publicly traded mutual funds, index funds, or similar pooling of securities. NOTE: Ownership of securities acquired as part of a stock purchase plan for employees during prior employment need not be disclosed, but additional purchases of such stock must be disclosed if in excess of 50% of MedTrust salary
· Acceptance of membership on the board of directors of any competitor, vendor, or client of MedTrust, or as a consultant or advisor to any such board of directors or to the management of such firm or person
· Lending money, guaranteeing debts, borrowing money, or accepting gifts or favors in a way that could appear to place an employee under obligations to a competitor, vendor or client of MedTrust
Confidential Information
In the course of performing your duties, you may, from time to time, be placed in a position of trust and confidence in which you receive or contribute to the creation of confidential, proprietary and/or government sensitive information, including classified information, relative to the operations of MedTrust or its clients. This confidential, proprietary and/or government sensitive information includes, but is not limited to: business, marketing, legal and accounting methods, policies, plans, procedures, strategies and techniques; information concerning MedTrust’s earnings and methods for doing business; research and development projects, plans and results; trade secrets (e.g., formulas, methods, processes and specifications) and technical information; trademarks; the names and addresses of MedTrust’s employees, suppliers, vendors, clients and potential clients; client lists; pricing, credit and financial information; other government sensitive information (i.e., classified material); and any other data or information relating to the business of MedTrust which is not generally known by and readily accessible to the public.
You may not use or disclose this confidential, proprietary and/or government sensitive information during your employment with us or after your employment with us has ended, except as necessary in the course of performing your job responsibilities for MedTrust and in furtherance of the company’s interests. In particular, all incoming calls or inquiries received concerning the company’s business activities must be referred to the appropriate manager or supervisor.
With regard to classified or unclassified sensitive information, MedTrust employees will strictly abide by the applicable laws and regulations.
Information About Competitors
To compete in the marketplace, it is necessary to gather competitive information fairly. But some forms of information-gathering can violate the law. At MedTrust, we are committed to avoiding illegal and improper information-gathering, so it is important to know what you can and cannot do and what you must be careful about.
Legitimate sources of competitive information include any publicly available information or that which is not subject to contractual or government disclosure restrictions. The following information should never be accepted or used by MedTrust employees:
· A competitor’s confidential or proprietary information, government sensitive information related to the competitor, or something similar belonging to anyone else.
· Confidential or proprietary information or government sensitive information related to a competitor in any form that new hires have from prior employers (including prior employment with the government).
· Non-public information about a competitor’s bid if you are involved in bidding, especially on government contracts.
· Information on a competitor that someone offers to sell.
If you come into possession of any of the above prohibited information, contact the Compliance Officer immediately.
Antitrust
MedTrust is fully committed to compliance with the antitrust laws, which are designed to promote free and open competition in the marketplace. Not only does the customer benefit by getting the best product at the lowest price, but MedTrust also benefits by being able to compete on a fair level playing field with competitors.
MedTrust competes for business, but some conduct in the name of competition is not consistent with the law or MedTrust’s commitment to integrity. Never compete by using unfair or illegal practices such as:
· Agreement among competitors to fix prices, rig bids, or engage in other anticompetitive activity
· Disparaging or false statements about competitors, their products or their services
· Stealing or misusing competitor’s trade secrets
· Cutting off a competitor’s sources of supply
· Inducing clients to break contracts with competitors
· Paying bribes to help MedTrust or to hurt a competitor
Accurate and Complete Books, Records and Accounting
The integrity and completeness of recordkeeping is not only MedTrust’s policy, it is also mandated by law. MedTrust is required to keep books, records, and accounts that fairly reflect the transactions and dispositions of its assets. Proper accounting for all transactions is essential to MedTrust’s control of its affairs and the accuracy of its financial reporting. To maintain the integrity of the accounting records, all entries in MedTrust’s books must be prepared carefully and honestly and must be supported by adequate documentation to provide a complete, accurate and auditable record of the transactions they describe. All employees have a responsibility to assure that their work is complete and accurate. No false or misleading entries may be made for any reasons, and no employee may assist another person in making such entries. These policies apply to all recordkeeping of financial records, and client and vendor reporting.
When the Government is Your Client
MedTrust does substantial business with government entities. While integrity is the foundation for all dealings with clients, special rules apply when the government is a client. Violations can result in criminal and civil penalties as well as exclusions from bidding on future government contracts.
Those involved in bidding on or providing service under a government contract need to know these rules:
· Never seek or accept confidential bid information or government sensitive information related to a competitor
· Never give or authorize the giving of any cash payment from MedTrust funds to any government official
· Never give or authorize the giving of payments in goods to any government official
· Never offer or provide gifts, gratuities or entertainment to any government official without prior written approval by the Compliance Officer
· Know and follow anti-kickback rules, including restrictions on gifts by those seeking business from the government and from government contractors, including suppliers in the supply chain to such contracts
· Conform strictly to the contract’s terms and conditions
· Billings must always be accurate, complete, and in full compliance with all rules and regulations
· Labor hours and other costs, especially when performed under cost-reimbursable, time and materials, and labor-cost type contracts must always be accurate, complete, and in full compliance with all rules and regulations
· Be truthful, accurate, and complete in all invoices, representations and certifications
· Know your government client’s specific rules and regulations
· Do not initiate any discussions about employment with any current or former government employee or agency with whom you have had a business relationship without first consulting the Compliance Officer. This includes employment with MedTrust or with a government agency.
Gifts, Meals and Entertainment
MedTrust’s business depends on creating productive successful relationships with vendors and clients. These relationships must be based on sound, fair business decisions.
MedTrust employees, nor any member of their families, may not offer to, solicit from, or accept from a supplier or customer, any gift or money that could be reasonably construed to be given to influence or give the appearance to influence the recipient. You should question any gift offered or given outside of the guidelines listed below and seek written approval from the Compliance Officer before taking action.
The following guidelines apply for gifts, entertainment and travel offered by MedTrust employees to suppliers and clients or offered to MedTrust employees from suppliers and clients. These guidelines recognize that modest, sensible gifts can be part of the normal course of doing business with other people.
MedTrust employees may provide clients, or accept from clients or suppliers, certain promotional “premiums” (such as t-shirts, coffee mugs, pens or key chains) imprinted with the Company logo or sales information. MedTrust employees may also offer clients, or accept from clients or suppliers, modest items of food, greeting cards or items with little intrinsic value (i.e., coffee, donuts, and certificates). No gift outside of these guidelines may be offered, given or accepted without prior written approval by the Compliance Officer.
There are clear and generally obvious forms of gifts, entertainment and travel that are NEVER allowed and constitute a clear violation of the Code of Conduct. These include:
· Cash (including chips for gambling), loans, stock, or stock options
· Any item which is provided in direct exchange (i.e., quid pro quo) for a reciprocal action
· Any item that is illegal, sexually explicit, or would violate MedTrust’s commitment of respect towards all those the company deals with
· Any item offered during the process of a competitive bid or contract negotiation with a vendor or client
· Any entertainment or travel or lavish gifts (e.g. airlines tickets, event tickets, club memberships, expensive jewelry, a computer system, etc.)
Compliance with Laws, Rules and Regulations
All employees must respect and obey the local, state and federal laws, rules and regulations applicable to MedTrust. Although not all employees are expected to know the details of these requirements, it is important to know enough to determine when to seek advice from supervisors, managers or the Compliance Officer.
If an employee is unsure of what laws, rules and regulations are applicable to his/her work with MedTrust, s/he should consult his/her supervisor or manager, or the Compliance Officer.
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Compliance