A. No, we will fully cooperate with any governmental investigation but the first thing that should be done is to contact the Compliance Officer who will determine the validity and scope of the governmental investigation. No patient information should be released to an investigator until the Compliance Officer confirms the validity of the investigation
The Hospital will at all times maintain professional and ethical standards in the conduct of its business. Each member of the Hospital Staff is expected to understand and adhere to the ethical standards as required by his/her profession and as defined by the Hospital’s mission, vision, values and Code of Conduct.
The Hospital requires honesty from all Hospital Staff members in the performance of their duties and in communication with all outside parties. No Hospital Staff member shall knowingly make false or misleading statements to any person or entity doing business with the Hospital.
Business transactions undertaken on behalf of the Hospital shall at all times be free from offers or solicitations of gifts or other improper inducements in exchange for influence on or assistance with the transaction. Offering, giving, soliciting or receiving any form of bribe or illegal inducement is expressly prohibited.
Hospital Staff may not utilize “insider” information for any business activity conducted by or on behalf of the Hospital. All business relations undertaken on behalf of the Hospital must be conducted at arm’s length.
It is the policy of the Hospital to manage and operate its business in a manner that respects the environment and conserves natural resources. Hospital Staff will utilize resources wisely, recycle when possible and otherwise dispose of waste in accordance with applicable laws and regulations.
I overheard a conversation between a pharmaceutical sales rep. and a coworker wherein the sales rep. offered the free use of the company’s time-share in Arizona. What should I do?
Hospital Staff who accept gifts, money or other items with other than nominal value from any person or organization that does business with the Hospital have violated the Code of Conduct. If such a situation arises, you should discuss it with the coworker and make sure he is aware of the standards of conduct. If you feel that the coworker intends to accept the gift, you should report the situation using the compliance concern reporting steps. Acceptance of gifts with other than nominal value will subject the staff member to discipline, up to and including termination of employment or association with the Hospital.
Health and Safety
The Hospital is committed to protecting the health and safety of Hospital Staff and to comply with all applicable health and safety laws and regulations. Hospital Staff are responsible for the prevention of accidents and for the reporting of unsafe practices or hazardous conditions that come to their attention.
I have been told by my supervisor to dispose of chemical waste down the drain and am concerned that this is not appropriate disposal for that particular chemical. What should I do?
Information regarding the hazards, handling and disposal of chemicals is contained in the
Material Safety Data Sheet binder that is available where hazardous materials are used. You
CORPORATE COMPLIANCE PLAN 5/6/10
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