1.9
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,
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.
1.11
Communications and Problem Solving It is the intent of the Company to deal fairly with all employees. In the event a problem, misunderstanding, or complaint occurs regarding an employee’s job evaluation, discipline, or other matters affecting the work relationship, the employee should follow the procedure below to resolve the issue.
Discuss the matter with the employee’s Direct Supervisor at the earliest possible time. Everyone benefits from efforts to settle the difficulty on its merits and without delay. If an employee believes the management team or a member of the management team is contributing to the problem, employees should contact Human Resources at the earliest available opportunity. If an employee feels they are unable to initiate resolution to the issue in this manner, proceed to Step #2.
At the employee’s request, another member of the management team or Human Resources can speak with the employee independently and, if appropriate, will mediate with the employee and the employee’s manager to discuss the facts of the issue in an effort to settle it.
If the matter continues to remain unresolved, at the employee’s request, the Chief Human Resources Officer (CHRO) or the CEO will meet with the employee independently. Based on this meeting and the facts gathered to date, the CHRO and/or the CEO will have the authority to determine a resolution which is in the best interest of both COPC and the employee.
If the employee’s complaint is of discrimination, sexual harassment or any form of unlawful or unwelcome harassment, the procedures set forth in Section 3.10, “Discrimination, Harassment and Sexual Harassment Prevention Policies and Complaint Procedure” should be followed.
Page 12
Made with FlippingBook - professional solution for displaying marketing and sales documents online