Code of Conduct

This Code of Conduct establishes the fundamental principles and standards that guide our actions at Keona Health. It applies to all employees, officers, directors, contractors, and representatives acting on behalf of Keona Health.

Table of Contents

  1. Introduction and Purpose
  2. Our Values
  3. Professional Standards and Ethics
  4. Healthcare Provider Interactions
  5. Anti-Corruption and Business Ethics
  6. Conflicts of Interest
  7. Gifts, Entertainment and Hospitality
  8. Social Media and Public Communications
  9. Fair Competition
  10. Financial Integrity
  11. Workplace Environment
  12. Environmental and Social Responsibility
  13. Reporting Violations
  14. Enforcement
  • Introduction and Purpose

    This Code of Conduct establishes the fundamental principles and standards that guide our actions at Keona Health. It applies to all employees, officers, directors, contractors, and representatives acting on behalf of Keona Health. While this Code provides guidance on ethical conduct, it works in conjunction with our detailed policies and procedures. Employees must familiarize themselves with all applicable company policies referenced in this document.

  • Our Values
    • Integrity: We act honestly and ethically in all our dealings
    • Excellence: We strive for the highest quality in everything we do
    • Innovation: We embrace creative solutions and continuous improvement
    • Respect: We treat everyone with dignity and professionalism
    • Responsibility: We are accountable for our actions and their impact
    • Patient Care: We prioritize the well-being and privacy of patients
  • Professional Standards and Ethics

    General Standards

    • Maintain professionalism in all business interactions
    • Follow all applicable laws, regulations, and company policies
    • Protect confidential information as outlined in Policy KH-02
    • Report any concerns or violations promptly
    • Complete all required training and certifications

    Compliance Requirements

    • Maintain compliance with HIPAA and other healthcare regulations
    • Follow all security policies outlined in Policy KH-02
    • Adhere to data protection requirements in Policy KH-24
    • Report compliance concerns according to Policy KH-08

Reporting & Enforcement

  • Reporting Violations

    Reporting Procedures

    • Report violations to supervisors or HR
    • Use anonymous reporting hotline: [Insert Hotline Number]
    • Email concerns to: compliance@keonahealth.com
    • Contact Legal Department directly

    Non-Retaliation

    • Prohibition on retaliation against reporters
    • Protection of confidentiality
    • Thorough investigation of all reports
    • Appropriate corrective action
  • Enforcement

    Compliance Monitoring

    • Regular audits and assessments
    • Training and education programs
    • Policy reviews and updates
    • Compliance certifications

    Violations and Consequences

    • Disciplinary action up to termination
    • Potential legal consequences
    • Requirement to report certain violations
    • Continuous improvement of controls
  • Healthcare Provider Interactions

    Professional Boundaries

    • Schedule appointments for provider meetings
    • Document all provider interactions
    • Provide only approved materials and resources

    Compliance Requirements

    • Follow Anti-Kickback Statute regulations
    • Document fair market value for consulting arrangements
    • Track aggregate spend on provider interactions
    • Maintain transparency in all relationships
    • Report any compliance concerns immediately

    Documentation

    • Maintain logs of all provider interactions
    • Record purpose and outcome of meetings
    • Document any resources provided
    • Keep records of any agreements or arrangements
    • Follow documentation requirements in Policy KH-12
  • Anti-Corruption and Business Ethics

    Anti-Corruption Policy

    • Zero tolerance for bribery and corruption
    • Prohibition on improper payments or benefits
    • Required due diligence on business partners
    • Accurate recording of all transactions

    Government Interactions

    • Special rules for government official interactions
    • Strict prohibition on payments to influence decisions
    • Required approval for government official meetings
    • Documentation of all government interactions
  • Conflicts of Interest

    Definition and Disclosure

    • Avoid situations where personal interests conflict with company interests
    • Disclose potential conflicts promptly
    • No use of company position for personal gain
    • Maintain objective business relationships

    Outside Activities

    • Obtain approval for outside employment or board positions
    • No competing with Keona Health
    • Disclose financial interests in competitors or suppliers
    • Report family relationships that could create conflicts
  • Gifts, Entertainment and Hospitality

    General Guidelines

    Maximum value limits:

    • $100 for business gifts
    • $250 for business entertainment
    • No gifts to government officials without legal approval

    Acceptable Practices

    • Modest business meals
    • Token promotional items
    • Reasonable entertainment in business settings
    • Holiday gifts of nominal value

    Prohibited Practices

    • Cash or cash equivalents
    • Gifts during contract negotiations
    • Gifts to government officials without approval
    • Lavish entertainment
    • Anything that could appear improper
  • Social Media and Public Communications

    Professional Standards

    • Never disclose confidential information
    • Maintain professional tone and language
    • Clearly distinguish personal from professional posts
    • No speaking on behalf of company without authorization
    • No photographs from healthcare facilities

    Content Guidelines

    • No patient information or images
    • No internal company information
    • No discussion of specific products/services without approval
    • No engagement in medical advice
    • No response to negative reviews or complaints

    Best Practices

    • Use privacy settings appropriately
    • Consider professional impact of all posts
    • Don't friend/follow patients
    • Don't engage in clinical discussions
    • Report any social media incidents
  • Fair Competition

    Antitrust Compliance

    • Compete fairly and ethically
    • No anti-competitive practices
    • No discussion of pricing with competitors
    • Respect competitive bidding processes

    Market Practices

    • Market services honestly
    • No disparagement of competitors
    • Gather competitive information legally
    • Maintain independence in pricing decisions
  • Financial Integrity

    Accurate Records

    • Maintain accurate and complete records
    • Follow proper accounting procedures
    • Document all business transactions
    • Retain records as required by law

    Financial Controls

    • Follow internal financial controls
    • Cooperate with audits
    • Report financial concerns promptly
    • Prevent and report fraud
  • Workplace Environment

    Equal Opportunity

    • Provide equal employment opportunities
    • Prohibit discrimination and harassment
    • Accommodate disabilities
    • Promote diversity and inclusion

    Professional Conduct

    • Treat all colleagues with respect
    • Maintain professional behavior
    • Support collaborative environment
    • Follow company policies and procedures
 

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