Code of Conduct (.pdf) - Geisinger Health System

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Integrity in Our Business Relationships BUSINESS CONFIDENTIALITY Health care is extremely competitive; our success depends in part on the unique nature of our programs, systems and information. Geisinger’s proprietary and business information must be kept confidential. This means that you must never share confidential business information with anyone – even friends and family members. There may also be times that you will even be asked to limit the information you share with people who work here at Geisinger. Accuracy is very important to our work at Geisinger. Paying strict attention to detail ensures that business sensitive information and protected health information in the form of records, mailings and other documentation is both accurate and complete. If you are unsure if you should be sharing information related to Geisinger with others, either within or outside the organization, ask your supervisor or contact the System’s Corporate Compliance Officer. It is very important that we all protect the confidentiality of vital business information. What kinds of business information must be kept confidential? Proprietary and confidential information includes non-public information related to: • Pricing and costs • Acquisitions, divestitures and other strategic relationships • Business and marketing plans • Clinic service or expansion plans • Staffing level plans • Employee and customer lists • Financial information • Research and quality data • Product/program planning • Privileged information, such as attorney-client communications or peer review information, and • Many other things that are important to the organization and our strategic or competitive position 6
Integrity in Our Business Relationships CONFLICTS OF INTEREST Conflicts of interest may occur if personal activities or interests would influence your ability to make decisions that are in the best interests of Geisinger. As a representative of Geisinger, you have a duty to act solely in the best interests of the organization, its patients and members. This means that you should not engage in activities that result in gain or profit for yourself or others at the expense of the organization, or that interfere with your work duties or judgment. The test for whether there is a conflict of interest is an objective test; that is, whether a conflict exists “in the eyes of a reasonable person,” not whether you think there might be a conflict. Geisinger currently maintains two separate Conflict of Interest Policies: (1) one applicable to directors, officers and senior leaders and (2) one applicable to all other employees. Geisinger also distributes an annual duality of interest questionnaire to certain employees to identify potential conflicts. If you do not routinely receive this questionnaire, or if a new potential conflict arises after you complete this questionnaire, please disclose these potential conflicts of interest to your supervisor or the Legal Department. Geisinger is legally obligated to protect its property and ensure its facilities and equipment are used appropriately. Resources such as materials, equipment, time and space should be used only for your work, unless your supervisor has specifically made an exception according to company policy. What’s a “conflict of interest?” It’s important to look at the facts and circumstances in order to decide if something is a conflict. A friendship with someone who works for a competitor is fine, but you should avoid talking about Geisinger with them, so that you don’t inadvertently disclose confidential information or put yourself or the organization in an inappropriate, or even illegal, situation. Some activities automatically create a conflict — such as being on the board of a competitor — while other activities may raise the possibility of a conflict — such as having a financial relationship with a competitor or vendor. That’s why it’s important to let your supervisor know if you are involved in any activities that may even just raise that possibility. Even the appearance of a conflict may have negative effects on both you and the organization. 7
Page 1 and 2: CODE OF CONDUCT “Make my hospital
Page 3 and 4: CODE OF CONDUCT LETTER FROM DR. STE
Page 5 and 6: SECTION 1 STANDARDS OF CONDUCT “I
Page 7: Integrity in Our Business Relations
Page 11 and 12: Integrity in Our Business Relations
Page 17 and 18: Integrity in Our Community Relation
Page 25 and 26: Integrity in Our Care and Service R
Page 27 and 28: Integrity in Our Care and Service R
Page 29 and 30: Integrity in Our Workplace Relation
Page 31 and 32: Integrity in Our Workplace Relation
Page 33 and 34: SECTION 2 CORPORATE COMPLIANCE PROG
Page 35 and 36: Corporate Compliance Program CORPOR
Page 37: Glossary of Terms Nonprofit purpose

Code of Conduct (.pdf) - Geisinger Health System

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