COPC Handbook December 2023 Q4

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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, favor, service, compensation in any form, discount, special treatment, or anything of monetary value. 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

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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.

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Service Animals Service animals are animals (primarily dogs) that are individually trained to do work or perform tasks for people with disabilities. Service animals are working animals, not pets. The work or task a service animal has been trained to provide must be directly related to the person’s disability and documentation. Employees may be asked to confirm that the service animal is required because of a disability and the work or task the animal has been trained to perform. Animals whose sole function is to provide comfort or emotional support do not qualify as service animals under the Americans with Disabilities Act (ADA). Under the ADA and Section 504 of the Rehabilitation Act of 1973, health care facilities must permit the use of a service animal by a person with a disability, including during a public health emergency or disaster. ● Service animals are to accompany the

● It may be appropriate to exclude a service animal from limited access areas that employ general infection control measures where the animal’s presence may compromise a sterile field environment. ● Service animals must be harnessed, leashed, or tethered, unless these devices interfere with the service animal’s work or if an individual’s disability prevents using these devices. The handler/owner must maintain control of the animal through voice, signal, or other effective controls. ● When encountering an individual with a service animal, do not interact with or distract the animal.

individual with a disability in all areas of COPC offices where employees, visitors, and patients are normally allowed during patient services, unless the animal’s presence or behavior creates a fundamental alteration in the nature of a facility’s services in a particular area or a direct threat* to other persons in a particular area. *A “direct threat” is defined as a significant risk to the health or safety of others that cannot be mitigated or eliminated by modifying policies, practices, or procedures. ● A person with a disability will be asked to remove their service animal from the premises if the animal is not housebroken, is out of control, or if the handler/owner does not take effective action to control the service animal.

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maintain an open-door policy with employees. Employees should feel free to discuss any questions, problems, complaints, or suggestions with any member of management.

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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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