1.8
Anti-Retaliation and Whistleblower This policy is designed to protect employees and address the commitment of COPC as it relates to integrity and ethical behavior in the workplace. In accordance with federal anti-retaliation and whistleblower protection regulations, COPC will not tolerate any retaliation against an employee who: ● Makes a good faith complaint or threatens to make a good faith complaint regarding
● Objects to or refuses to participate in any activity, policy, or medical practice which the employee reasonably believes is a violation of the law. ● Provides information to assist in an investigation regarding violations of the law. ● Files, testifies, participates, or assists in a proceeding, action or hearing in relation to alleged violations of the law.
suspected company or employee violations of the law, including discrimination or other unfair employment practices. ● Makes a good faith complaint or threatens to make a good faith complaint regarding accounting, internal accounting controls, or auditing matters that may lead to incorrect or misrepresentations in financial accounting. ● Makes a good faith report or threatens to make a good faith report of a violation that endangers the health or safety of an employee, client, or patient, environment, or the general public. Conflict of Interest A conflict of interest occurs when an employee’s personal interests interfere, or appear to interfere, with the employee’s ability to make sound business decisions on behalf of the Company. COPC employees have a responsibility to avoid any real or potential conflicts of interest as outlined in the guidelines below. Conflicts of interest include, but are not limited to the following scenarios: ● When an employee is in a position to influence a decision or have business dealings on behalf of COPC that might result in a personal gain for the employee or for one of the employee’s relatives or friends. ● A conflict of interest may occur when an employee has financial interest in a business or venture that may conflict with the interests of COPC. ● A personal gain is defined as a gift, gratuity,
1.9
COPC does not automatically assume that there is a conflict of interest when an employee has a relationship with another company. By informing COPC that there is the possibility of an actual or potential conflict of interest, COPC has the opportunity to establish safeguards to protect everyone involved. All inquiries will be kept confidential to the maximum extent possible. Employees should consult with the Compliance or Legal Departments when circumstances are such that there is a question regarding a potential conflict of interest. Failure to identify a conflict of interest may result in disciplinary action, up to and including termination of employment. This policy is not intended to restrict an employee’s right to discuss, or act together to improve, wages, benefits, and working conditions with co-workers or in any way restrict employees’ rights under the National Labor Relations Act.
favor, service, compensation in any form, discount, special treatment, or anything of monetary value.
1.10
Open Door COPC welcomes the opportunity to discuss business, employee, and/or patient-related concerns and suggestions for improvements to business operations, employment experience, and/ or patient care as a whole and strives to maintain
an open-door policy with employees. Employees should feel free to discuss any questions, problems, complaints, or suggestions with any member of management.
Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813
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