Negotiating Standard Terms and Conditions/Best Price Arrangements with EHR Vendors
|
|
- Nigel Sims
- 5 years ago
- Views:
Transcription
1 Negotiating Standard Terms and Conditions/Best Price Arrangements with EHR Vendors Gerry Hinkley Co-Chair, Health Care Industry Team Pillsbury Winthrop Shaw Pittman LLP National REC and HIE Summit West October 4 6, 2010 San Francisco
2 Overview EHR Acquisition in an REC (don t say Wreck ) Context RECs are changed to Identify two or more certified EHR products that they have fully evaluated Assist in identifying the product that is a best match for a providers needs Assist the providers in achieving effective implementation Enhancing clinical and administrative workflows to improve quality and value of care, including patient experience as well as outcome of care Observing and complying with applicable legal, regulatory, professional and ethical requirements to protect the privacy and security of health information Achieving exchange of health information in compliance with applicable statutory and regulatory requirements, and patient preferences. 2
3 Overview the REC Opportunities RECs present the opportunities to enable comparison shopping achieve best pricing streamline procurement streamline implementation training data transfer work flow redesign implement minimum necessary help provider empower consumers understand privacy practices access to information actively engage in their care 3
4 REC as Group Purchasing Organization What do big purchasers do? Do business on their own terms Have a systematic procurement policy and process Utilize a standard software license and services agreement Impose a vendor code of conduct Impose a vendor confidentiality standard RECs provide the opportunity for providers to do business this way 4
5 Standard of Confidentiality Beyond the Business Associate Vendor will not process or otherwise use any personal information for any purpose other than performing the specified services for Customer and as instructed by Customer Any personal information collected or accessed by Vendor in the performance of the specified services shall be limited to that which is necessary to perform such services or to fulfill any legal requirements If the services involve the collection of personal information directly from individuals, such as through a registration process or a webpage, Vendor will provide a clear and conspicuous notice regarding the uses of the personal information, which notice shall be consistent with the provisions of the agreement between Vendor and Customer 5
6 Standard of Confidentiality Beyond the Business Associate 2 No terms of use, privacy statement or other provisions presented to individuals via a webpage or in any other manner shall alter the Vendor's obligations or rights under this Standard or the manner in which the Vendor may use personal information Vendor shall not transfer the personal Information across any national borders or permit remote access to the personal information from third party unless such transfer or remote access conforms to the Electronic Security Standard Vendor shall adhere to the Physical Security Standard Vendor shall adhere to the Data Access Standard 6
7 Vendor Rules of Conduct Always engage the REC representative in any procurement activity Restrain from offering gifts, entertainment or favors to Customer employees or their families. Gifts and entertainment include, but are not limited to items such as, tickets to sporting events and invitations for participation in activities such as golf Restrain from offering to pay for meals unless for a specific business purpose with an appropriate opportunity for Customer to reciprocate. Meals must be of reasonable cost (not lavish) 7
8 Vendor Rules of Conduct 2 Restrain from offering to pay for Customer employees and/or family members travel, lodging, and/or entertainment associated with meetings or seminars Restrain from holding meetings with Customer employees at locations that may be perceived as inappropriate by the business community 8
9 Toward a Simplified License and Services Agreement The EHR industry is languishing in a miasma of complicated documents and indecipherable exhibits What is a miasma -- a vaporous exhalation believed to cause disease License Agreement Services Agreement Purchase or Delivery Order Statement of Work $$$$$$$$$$$$$$$ 9
10 Standard Terms and Conditions Acceptance Acceptance Testing Documentation Installation Products Services Software Specifications Update/Release 10
11 Standard Terms and Conditions 2 Scope of license Sublicensing Source code Ownership of products by Vendor Limitations on Customer: reverse engineer, secure storage, unauthorized reproduction Invoices Fees and charges Warranty of functionality Infringement warranty 11
12 Group Pricing Issues What do GPOs do? Better prices for customers Improve quality, reliability, and service for members purchasing activities Improve products and services Steps to avoid antitrust enforcement Market power (35-40% of market is safety zone) Avoid potential for price-fixing collusion among purchasers if goods purchased are substantial part of overhead (> 20% of revenues) Limit member information that is gathered and shared to avoid collusive overflow Emphasize pro-competitive benefits of GPOs in helping members to reduce costs, maintain or expand offerings and charge lower prices Develop antitrust guidelines and training for customers 12
13 Take Aways RECs provide opportunities for providers to participate in group purchasing to improve pricing services products RECs have the potential to improve documentation improve the vendor-customer relationship improve the provider-patient relationship 13
14 14 The purpose of this presentation is to inform and comment upon recent developments in health law. It is not intended, nor should it be used, as a substitute for specific legal advice legal counsel may only be given in response to inquiries regarding particular situations.
15 Contact Information Gerry Hinkley Pillsbury Winthrop Shaw Pittman LLP 50 Fremont Street San Francisco, CA Direct: (415)
Managing an Effective Procurement Process at the State Level
Managing an Effective Procurement Process Gerry Hinkley 415.983.1135 gerry.hinkley@pillsburylaw.com Pillsbury Winthrop Shaw Pittman LLP Overview Mission, vision, governance and leadership Fitting procurement
More informationAcknowledgement of Aramco Overseas Company BV. Supplier Code of Conduct
IMPORTANT DOCUMENT PLEASE RETURN SIGNED ACKNOWLEDGEMENT Acknowledgement of Aramco Overseas Company BV Supplier Code of Conduct (Applicable to Vendors, Manufacturers, Contractors and Sub-Contractors) Aramco
More informationEstablished May 1, 2001, revised April 4, 2011
Established May 1, 2001, revised April 4, 2011 Introduction - What is the? The sets the standards of behavior for Company directors and employees. By following the code, we conduct activities in compliance
More informationMunicipality of the District of Lunenburg POLICY
Municipality of the District of Lunenburg Title: Purchasing and Tendering Policy Policy No. MDL-33 Effective Date: January 1, 2014 1. Purpose and Objectives POLICY Amended Date: January 12, 2016 The Municipality
More informationAcceleron Pharma Inc. Code of Business Conduct and Ethics
I. INTRODUCTION Acceleron Pharma Inc. Code of Business Conduct and Ethics (Amended & Restated as of March 1, 2018) This Code of Business Conduct and Ethics ( Code ) provides a general statement of the
More informationAssume that any action you take could ultimately be publicized, and consider how you and PCA would be perceived. When in doubt, stop and reflect.
CODE OF ETHICS ( Code ) 8.1 Purpose The purpose of the Code of Ethics and Business Conduct is to set forth basic principles to guide you in your day-to-day activities as an employee, officer, or director
More informationTable of Contents I. Introduction... 3 II. URAC Values and Business Ethics... 3 Values... 3 Business Ethics... 3 III. Compliance with Laws and
URAC Code of Conduct December 10, 2015 Table of Contents I. Introduction... 3 II. URAC Values and Business Ethics... 3 Values... 3 Business Ethics... 3 III. Compliance with Laws and Regulations... 4 IV.
More informationCORPORATE POLICIES AND PROCEDURES. GIFTS NO.: (Formerly ADM X 260)
CORPORATE POLICIES AND PROCEDURES GIFTS NO.: 00365 (Formerly ADM X 260) ISSUED BY: V.P. Human Resources DATE OF APPROVAL: 2008/10/08 APPROVED BY: Senior Management LAST REVIEW/REVISION DATE: Committee
More informationDATA SHARING AGREEMENT
DATA SHARING AGREEMENT Effective Date: This Data Sharing Agreement ( Agreement ) is effective as of the Effective Date between EMD Serono, One Technology Place, Rockland, MA 02370 and Name ( Institution
More informationCARNIVAL CORPORATION & PLC
CARNIVAL CORPORATION & PLC Business Partner Code of Conduct and Ethics A Letter from our CEO Building and maintaining trust in our business relationships and pursuing the highest standards of ethical behavior
More informationCODE OF ETHICS AND BUSINESS CONDUCT FOR EMPLOYEES OF THE CORPORATION FOR PUBLIC BROADCASTING. Revised April 21, 2010
CODE OF ETHICS AND BUSINESS CONDUCT FOR EMPLOYEES OF THE CORPORATION FOR PUBLIC BROADCASTING Revised April 21, 2010 INTRODUCTION The purpose of this Code is to assure that employees of CPB act in the best
More informationSAP Partner Code of Conduct October 26, V2
SAP Partner Code of Conduct October 26, 2016- V2 Introduction Integrity and transparency constitute a cornerstone for the way in which SAP does business. SAP expects you, as a Partner, to do business in
More informationAnderson Compliance Program
POLICY: Gifts, Gratuities and Business Courtesies 02/15 Anderson Compliance Program GIFTS, GRATUITIES, AND BUSINESS COURTESIES POLICY Purpose: The federal anti-kickback statute prohibits the acceptance
More informationI. Procurement. Procurement Authority. Ethical Conduct, Conflict of Interest. DU Procurement Policy
I. Procurement Procurement of goods and services for the university must be conducted in an open and competitive environment to ensure that prices paid are fair and reasonable. Purchasing activities are
More informationAnti-Bribery and Anti-Corruption Guide for Third Party Sellers working for or on behalf of Cardinal Health
Anti-Bribery and Anti-Corruption Guide for Third Party Sellers working for or on behalf of Cardinal Health Our COMMITMENT& EXPECTATIONS This guide is designed to help you understand our anti-bribery and
More informationBMO FINANCIAL GROUP PROCUREMENT ETHICS GUIDE
BMO FINANCIAL GROUP PROCUREMENT ETHICS GUIDE Purpose The Procurement Ethics Guide sets out how BMO Financial Group (BMO) personnel should deal with suppliers. The Guide reflects the high ethical standards
More informationEthics, Conflicts of Interest and Acceptance of Gifts HC 5.110
All Metropolitan Nashville Public Schools (MNPS) employees are required to abide by all federal, state and local government laws. MNPS employees must also maintain the highest level of honesty, integrity,
More informationPolicy Name: McKesson s Imaging and Workflow Solutions and Enterprise Information Solutions U.S. - EU Safe Harbor Privacy Policy ( Policy )
Overview: McKesson is committed to maintaining the privacy and security of Personal Information. This Policy establishes the principles that govern the Processing of Personal Information received from
More informationSupplier Code of Ethics
INTRODUCTION ATS is committed to conduct business in a professional, honest and ethical manner, and to comply with the law wherever it conducts business. ATS expects all Suppliers to conduct their business
More informationGIFTS, GRATUITIES AND BUSINESS COURTESIES
GIFTS, GRATUITIES AND BUSINESS COURTESIES Policy Statement This policy is intended to provide guidance for appropriate decision- making regarding the Acceptance, solicitation and/or provision of gifts
More informationFOUNDATION BUILDING MATERIALS, INC. EMPLOYEE CODE OF CONDUCT
FOUNDATION BUILDING MATERIALS, INC. EMPLOYEE CODE OF CONDUCT Foundation Building Materials, Inc. (the Company ) conducts its business in accordance with the highest ethical standards of corporate leadership
More informationDRAFT. Takeda Supplier Code of Conduct. Version 1.0
Takeda Supplier Code of Conduct Version 1.0 June 24, 2015 Table of Contents 1.0 Introduction & Applicability... 2 2.0 Adherence to Applicable Laws, Regulations & Supplier Code... 3 3.0 Business Practices...
More informationFive Minutes on Empowering Modern Procurement. Why Transforming Procurement Is a Top Priority for the Modern Business
Five Minutes on Empowering Modern Procurement Why Transforming Procurement Is a Top Priority for the Modern Business While there has been an increase since 2011 in those claiming strong relationships and
More informationGlobal Supplier Code of Business Conduct & Ethics
Global Supplier Code of Business Conduct & Ethics Version 2.0 2/15/2017 Contents Document Statement... 3 Scope... 3 1.0 Related or Referenced Policies... 3 2.0 Compliance with Laws, Regulations and the
More informationBusiness Relationship Statement
Business Relationship Statement WELCOME Dear HealthTrust Suppliers and Potential Suppliers, Thank you for all you do to support our members and other healthcare providers. Without your cooperation, HealthTrust
More information>> INFRASERV HÖCHST GROUP CODE OF CONDUCT. What matters to us
>> INFRASERV HÖCHST GROUP CODE OF CONDUCT What matters to us INFRASERV HÖCHST GROUP CODE OF CONDUCT (DATE: 11.10.2016) WHAT MATTERS TO US 03 WE PROVIDE FAIR WORKING CONDITIONS 05 WE WORK SAFELY AND RESPONSIBLY
More informationCode of Conduct. Page1 INTRODUCTION CODE OF CONDUCT
1. EMPLOYMENT PRACTICES 2. TRADEMARKS 3. ANTI-CORRUPTION 4. GIFTS / CONFLICTS OF INTEREST 5. ENVIRONMENT 6. PERSONAL INFORMATION 7. BUSINESS RECORDS 8. PRESS 9. REPORT IT Code of Conduct INTRODUCTION CODE
More informationOilfield Service Co.
Oilfield Service Co. Peak Oilfield Service Company Code of Business Ethics and Compliance From the President Our role in supporting the oil and gas industry is simple: we provide capable, satisfi ed employees
More informationGovernment Contractors Face Expanded Affirmative Action Requirements Regulations relate to veterans and individuals with disabilities.
Client Alert Government Contracts & Disputes Nonprofit Organizations March 20, 2014 Government Contractors Face Expanded Affirmative Action Requirements Regulations relate to veterans and individuals with
More informationBusiness Conduct Requirements for Representatives and Channel Partners
Business Conduct Requirements for Representatives and Channel Partners www.qorvo.com Qorvo, Inc. and its affiliates ( Qorvo ) are committed to the highest standards of business conduct and ethics and expect
More informationUNIVERSITY of HOUSTON MANUAL OF ADMINISTRATIVE POLICIES AND PROCEDURES
UNIVERSITY of HOUSTON MANUAL OF ADMINISTRATIVE POLICIES AND PROCEDURES SECTION: Procurement Number 04.00.00 AREA: Reference SUBJECT: Code of Conduct - Procurement Responsibilities I. PURPOSE AND SCOPE
More informationCODE OF CONDUCT FOR DOING BUSINESS WITH LINKEDIN
CODE OF CONDUCT FOR DOING BUSINESS WITH LINKEDIN TABLE OF CONTENTS INTRODUCTION 1 Expectations LINKEDIN VALUES 2 MAINTAINING BUSINESS INTEGRITY 3 Anti-Corruption Competition Laws PROMOTING TRANSPARENCY
More informationBob Evans Farms, Inc.
Bob Evans Farms, Inc. Guidelines for Business Gifts and Entertainment Adopted by the Board of Directors June 4, 2011 Amended and Restated as of February 25, 2014 Overview Our Company has a Code of Conduct
More informationHow to Select a Certified EHR
How to Select a Certified EHR Selecting an EHR system is a critical decision and a significant planning task. There are different opinions regarding when the selection of an EHR system should be made in
More information3.6.2 Internal Audit Charter Adopted by the Board: November 12, 2013
3.6.2 Internal Audit Charter Adopted by the Board: November 12, 2013 I. PURPOSE The purpose of this Charter is to formally define LACERS internal audit function s purpose, authority, and responsibility.
More informationSUPPLY CHAIN MANAGEMENT POLICY
SUPPLY CHAIN MANAGEMENT POLICY PURPOSE The purpose of this policy is to ensure timely and fiscally sound procurement processes. The University of Texas MD Anderson Cancer Center (MD Anderson) will assume
More informationGuide to North America Healthcare Compliance 2016/2017
Guide to North America Healthcare Compliance 2016/2017 Dr. Reddy s Laboratories, Inc. NOTICE: this information is provided pursuant to the requirements of California Health & Safety Code 119400, 119402,
More informationTABLE OF CONTENTS SUMMARY PURCHASING PROCEDURES
May 2014 TABLE OF CONTENTS SUMMARY PURCHASING PROCEDURES (1) Levels of Purchasing Authority (2) Identify Need (3) Develop Specifications (4) Purchases Exempt from Purchasing Procedures (5) Special Requirement
More informationSTEPS FOR EFFECTIVE MANAGEMENT OF VENDOR AND SUPPLIER CYBERSECURITY RISKS. April 25, 2018 In-House Counsel Conference
STEPS FOR EFFECTIVE MANAGEMENT OF VENDOR AND SUPPLIER CYBERSECURITY RISKS April 25, 2018 In-House Counsel Conference Presenters: Daniela Ivancikova, Assistant General Counsel, University of Delaware Evan
More informationANTI-BRIBERY AND CORRUPCION (PUBLIC SECTOR) POLICY
ANTI-BRIBERY AND CORRUPCION (PUBLIC SECTOR) POLICY Doing the right thing, the right way and if you see or suspect something wrong Say it! ANTI-BRIBERY AND CORRUPCION (PUBLIC SECTOR) POLICY 1. INTRODUCTION
More informationSALINAS VALLEY MEMORIAL HEALTHCARE SYSTEM. Compliance Program. March 2018
SALINAS VALLEY MEMORIAL HEALTHCARE SYSTEM Compliance Program March 2018 Salinas Valley Memorial Healthcare System, 450 East Romie Lane, Salinas, California, 93901 PROGRAM GOAL/PURPOSE The Salinas Valley
More informationManager, Sourcing Supply and Contracts, Grid Projects Approved By:
Procurement Policy ISSUE DETAILS Effective Date: 1 Policy Owner: Chief Executive Officer Written By: Manager, Sourcing Supply and Contracts, Grid Projects Approved By: Transpower Board of Directors Minute
More informationETHICAL CODE OF CONDUCT
S E C U R I N G T H E F U T U R E ETHICAL CODE OF CONDUCT 1 TABLE OF CONTENT 1. THE ETHICAL CODE OF CONDUCT 4 1.1 Purpose 4 1.2 Commitment 5 1.3 Presentation of the Code of Conduct 5 2. GENERAL PRINCIPLES
More informationTHE TIMBERLAND COMPANY CODE OF ETHICS
THE TIMBERLAND COMPANY CODE OF ETHICS Code of Ethics MISSION AND VALUES STATEMENT We believe the honest and ethical conduct of our employees is an essential prerequisite to our success as a company. There
More informationVoluntary Code of Business Ethics in Vietnamese Biopharmaceutical Sector
Voluntary Code of Business Ethics in Vietnamese Biopharmaceutical Sector I/ Preamble: In September 2010 at the conference at ministerial level (Ministers of Foreign Affairs and Ministers of Trade), APEC
More informationWORLD HEALTH ORGANIZATION. Guidelines on working with the private sector to achieve health outcomes
WORLD HEALTH ORGANIZATION EXECUTIVE BOARD 107th Session 30 November 2000 Provisional agenda item 8.3 Guidelines on working with the private sector to achieve health outcomes Report by the Secretariat 1.
More informationCDM Smith Code of Ethics
CDM Smith Inc. and all of its subsidiaries are committed to ethical conduct in our business practices. Since the firm s founding in 1947, we have always upheld a policy to conduct all business in a lawful
More informationYou Might Have a HIPAA Breach. Now What?
You Might Have a HIPAA Breach. Now What? Ann M. Curran O Connor & Thomas, PC Phuong D. Nguyen Compliance Manager HealthTexas Provider Network Introductions Phuong D. Nguyen Compliance Manager, HealthTexas
More informationYou Might Have a HIPAA Breach. Now What?
You Might Have a HIPAA Breach. Now What? Ann M. Curran O Connor & Thomas, PC Phuong D. Nguyen Compliance Manager HealthTexas Provider Network Introductions Phuong D. Nguyen Compliance Manager, HealthTexas
More informationCODE OF CONDUCT. (As Amended June 11, 2015)
CODE OF CONDUCT (As Amended June 11, 2015) 1. INTRODUCTION Employees of Facebook, Inc., or any of its affiliates or subsidiaries, ( Facebook ) and others performing work for Facebook or on its behalf,
More informationFDA's New Import Program for Strict Precision
FDA's New Import Program for 2019 - Strict Precision *** LIMITED TIME OFFER: FREE $100 AMAZON GIFT CARD! *** REGISTER TODAY! The FDA continues to change its import program to better manage new problems
More informationIngram Micro Code of Conduct
Ingram Micro Code of Conduct 2015 Ingram Micro Inc. 1 Objectives The purpose of this training is to familiarize associates with the Ingram Micro Code of Conduct and more broadly help them understand and
More informationCODE OF CONDUCT A MESSAGE FROM OUR CEO. Dear Colleagues:
CODE OF CONDUCT A MESSAGE FROM OUR CEO Dear Colleagues: Few things are as important as your reputation. That s true for companies and individuals alike. Logitech s ethical reputation is the foundation
More informationEngineering Ethics Seminar JSC - NASA Don Johnson, P.E. NLT Management Systems
Engineering Ethics Seminar JSC - NASA 2014 Don Johnson, P.E. NLT Management Systems Two Ethics Rules Engineers Shall Protect the Public Two Ethics Rules Engineers Shall Protect the Public Engineers Shall
More informationGDPR BEST PRACTICES ESSENTIAL PROCESSES TO MEET THREE KEY OBLIGATIONS
GDPR BEST PRACTICES ESSENTIAL PROCESSES TO MEET THREE KEY OBLIGATIONS 1 The General Data Protection Regulation (GDPR) has 99 Articles and one clear intent: to protect the personal data of EEA/EU citizens.
More informationORDER-TO-CASH INVENTORY MANAGEMENT
RSM TECHNOLOGY ACADEMY Syllabus and Agenda ORDER-TO-CASH INVENTORY MANAGEMENT FOR MICROSOFT DYNAMICS AX Course Details 3 Audience 3 At Course Completion 3 Course Cancellation Policy 4 Guaranteed to Run
More informationPurchase Card Program
Purchase Card Program POLICIES AND PROCEDURES South Puget South Community College has established a Purchase Card Program in accordance with the Office of Financial Management and the Department of Enterprise
More informationCODE OF BUSINESS CONDUCT AND ETHICS
CODE OF BUSINESS CODE OF BUSINESS INTRODUCTION At Cathedral Energy Services Ltd. and its subsidiaries (together, Cathedral ), we have always recognized the value of growing and developing trusting relationships
More informationCalifornia Institute of Technology BUSINESS EXPENSE GUIDELINES: ENTERTAINMENT. Office of Financial Services
California Institute of Technology BUSINESS EXPENSE GUIDELINES: ENTERTAINMENT Office of Financial Services Entertainment Page 2 Contents 1. Purpose... 3 2. Scope... 3 3. Definitions... 3 4. Institute Guidelines...
More informationFinance System Users are Employees or Affiliate Fiscal Staff with access to the Finance System.
ADMINISTRATIVE POLICY POLICY NUMBER: PAGE NUMBER Page 1 of 5 CHAPTER: ADAMS STATE COLLEGE SUBJECT: Fiscal Code of Ethics RELATED POLICIES: C.R.S. 24-18-101 through 24-18- 105, and 24-18-108 through 24-18-110
More informationSalesforce s Processor Binding Corporate Rules. for the. Processing of Personal Data
Salesforce s Processor Binding Corporate Rules for the Processing of Personal Data Table of Contents 1. Introduction 3 2. Definitions 3 3. Scope and Application 4 4. Responsibilities Towards Customers
More informationINTEGRITY COMPLIANCE PROGRAM
INTEGRITY COMPLIANCE PROGRAM Corporate family: MG Mind Ltd, Mrkonjić putevi Ltd, Merkur Ltd. and all legal entities which are directly or indirectly controlled by the General Assemblies of MG Mind Ltd.,
More informationSTC s Supplier Code of Conduct
STC s Supplier Code of Conduct 25 In the name of Allah The Most Gracious, The Most Merciful Dear Valued Supplier, Saudi Telecom Company has a strong and long-term commitment to social responsibility. It
More informationsupplier code of conduct
supplier code of conduct SUPPLIER CODE OF CONDUCT Page 1 of 4 Purpose Catalent is a leading provider of innovative development services, advanced delivery technologies and integrated supply solutions to
More informationBest Buy Political Activity &
Page 1 of 7 A. Policy Overview Purpose: This policy seeks to educate employees on political activity as it pertains to employment with Best Buy as a U.S.-domiciled company. Best Buy encourages employees
More informationFAIRNESS REPORT INCREMENTAL REGULATION CAPACITY REQUEST FOR PROPOSAL ISSUED: JUNE 29, 2017 INDEPENDENT ELECTRICITY SYSTEM OPERATOR PREPARED FOR THE:
FAIRNESS REPORT INCREMENTAL REGULATION CAPACITY REQUEST FOR PROPOSAL ISSUED: JUNE 29, 2017 PREPARED FOR THE: INDEPENDENT ELECTRICITY SYSTEM OPERATOR JANUARY 19, 2018 TABLE OF CONTENTS 6 Introduction and
More informationEthics and integrity. Compliance: A guide for third parties
Ethics and integrity Compliance: Doing the right thing together Living up to our ethical standards is not only the right thing to do, but it is also critical to the efficiency and reliability of our operations.
More informationDeclaration Pursuant to California Health and Safety Code (e)
Declaration Pursuant to California Health and Safety Code 119402(e) Bausch + Lomb is committed to upholding the highest standards of business conduct and ethics in its relationships with its customers,
More informationWilo Group Code of Conduct. "Responsible Behaviour
Wilo Group Code of Conduct "Responsible Behaviour January 2011 CONTENT FOREWORD 2 SCOPE 3 WILO PRINCIPLES 4 BASIC SOCIAL PRINCIPLES 4 COMPLIANCE OF LAWS 4 CONFLICTS OF INTEREST 4 ENVIRONMENTAL PROTECTION
More informationCHOICE HOTELS INTERNATIONAL, INC. CORPORATE ETHICS POLICY
PURPOSE AND SCOPE CHOICE HOTELS INTERNATIONAL, INC. CORPORATE ETHICS POLICY The Board of Directors of Choice Hotels International, Inc. and its subsidiaries ( Choice ) established and updates this Corporate
More informationBest Buy Political Activity & Government Relations Policy
Best Buy Political Activity & Government Relations Policy Employee Policy B e s t B u y C o., I n c. G o v e r n m e n t R e l a t i o n s D e p a r t m e n t This policy seeks to educate employees on
More informationCode of Conduct Revised Feb 2012
Code of Conduct Revised Feb 2012 Table of Contents Introduction 2 1.0 Policy Statement and Objective 3 2.0 Application and Scope 5 3.0 Responsibility for Administration 6 4.0 Required Conduct 9 5.0 Business
More information6-1 E-MARKETING 5/E. Part III: E-Marketing Strategy. Chapter 6: E-Marketing Research Pearson Education, Inc. Publishing as Prentice Hall
6-1 E-MARKETING 5/E Part III: E-Marketing Strategy Chapter 6: E-Marketing Research Chapter 6 Objectives 6-2 After reading Chapter 6, you will be able to: Identify the three main sources of data that e-
More informationPHARMACEUTICAL SPONSORSHIP WORKING WITH INDUSTRY POLICY
PHARMACEUTICAL SPONSORSHIP WORKING WITH INDUSTRY POLICY Document Owner Luton CCG Document Author Head of Medicines Optimisation Directorate Quality and Clinical Governance Ratifying Committee CCG Board
More informationGifts, Benefits and Hospitality Policy
Gifts, Benefits and Hospitality Policy 1. Purpose Phillip Island Nature Parks (the Nature Parks) accepts that gifts, benefits and hospitality will be offered to employees and Board Members from time to
More informationGeneral Policies & Procedures. SV 5.0 Clean Harbors Vendor Code of Business Conduct and Ethics
1. Purpose This Code is intended to govern the conduct of Clean Harbors, Inc. and all of its subsidiaries Vendors when doing business with or on behalf of Clean Harbors, Inc. For the purpose of this Code,
More informationINTERNATIONAL DIGITAL PUBLISHING FORUM ANTITRUST COMPLIANCE POLICY AND GUIDELINES
INTERNATIONAL DIGITAL PUBLISHING FORUM ANTITRUST COMPLIANCE POLICY AND GUIDELINES It is the policy of the International Digital Publishing Forum ("IDPF" or "the Forum") to comply with all antitrust and
More informationLIFEBRIDGE HEALTH INTEGRITY PROGRAM CODE OF EXCELLENCE
LIFEBRIDGE HEALTH INTEGRITY PROGRAM CODE OF EXCELLENCE I. MESSAGE FROM THE PRESIDENT It is the mission of LifeBridge Health to provide a broad array of high quality, cost effective health and health related
More informationDrafting a Code of Ethics. Carl Sniffen, Member USATF Ethics Committee
Carl Sniffen, Member USATF Ethics Committee carlsniffen@gmail.com 503-577-8955 Objectives: Why do you need a Code of Ethics ( COE ) and/or Conflicts of Interest ( COI ) provisions? What s the difference
More informationCODE OF CONDUCT. At HITT, our focus goes beyond simply getting the job done; it s about how we conduct ourselves while we do it.
At HITT, our focus goes beyond simply getting the job done; it s about how we conduct ourselves while we do it. Our team members actions are a direct representation of the company an organization that
More informationOur Lady of Lourdes Health Care Services, Inc. and Affiliates POLICY NUMBER: AS0047CCP. PAGE NUMBER: 1 of 11
PAGE NUMBER: 1 of 11 ACCOUNTABILITY: President and Chief Executive Officer OBJECTIVES: RELATION TO MISSION: Our Lady of Lourdes, a Catholic Health System dedicated to its Franciscan Tradition of serving
More informationEVROSTON ECONOMICS AND MANAGEMENT CONSULTANTS CORPORATE BUSINESS ETHICS POLICY
EVROSTON ECONOMICS AND MANAGEMENT CONSULTANTS CORPORATE BUSINESS ETHICS POLICY JANUARY 2012 CORPORATE BUSINESS ETHICS POLICY TABLE OF CONTENTS Page 1. INTRODUCTION 2 2. COMPLIANCE WITH LAW AND REGULATIONS
More informationYOUR COMPLIANCE TEAM S EXCLUSIVE ACCESS SUPPLY CHAIN SUMMIT SERIES LONDON CHICAGO SAN DIEGO
YOUR COMPLIANCE TEAM S EXCLUSIVE ACCESS SUPPLY CHAIN SUMMIT SERIES LONDON CHICAGO SAN DIEGO WHY SHOULD YOU SEND YOUR COMPLIANCE TEAM TO THE SUPPLY CHAIN SUMMIT SERIES? The Supply Chain Summit Series provides
More informationCode of Ethics and Conduct Policy
Code of Ethics and Conduct Policy Policy statement Transpower s purpose is to connect New Zealanders to their power system, through safe, smart solutions for today and tomorrow. In working to achieve our
More informationCODE OF CONDUCT DESCRIPTION PRINCIPLES POLICIES AND DEFINITIONS
CODE OF CONDUCT DESCRIPTION Schneider has adopted the following Code of Conduct ( Code ) to apply to Schneider s directors, officers, managers and associates. While no code or policy can anticipate every
More informationShipping & Mailing Outbound and Inbound Package Management. SendSuite Live. Global logistics management made easy.
Shipping & Mailing Outbound and Inbound Package Management SendSuite Live Global logistics management made easy. Managing an outbound shipping operation is a big expense, regardless of your operation s
More informationSupplier Ethical Expectations
Supplier Ethical Expectations Training for Suppliers and Their Employees Revision 9, 2017 Course ID 00016572 1 Overview 1. What Intel Expects of Intel Employees Intel s Code of Conduct Intel s Anti-corruption
More informationAdvaMed Code of Ethics Case Studies
AdvaMed Code of Ethics Case Studies Health Care Compliance Association 2006 Compliance Institute Vickie McCormick 612.204.4156 vmccormick@halleland.com Approaching the Case Studies Approach Review common
More informationUNICEF s Procurement Processes and Tendering for Diagnostics
UNICEF s Procurement Processes and Tendering for Diagnostics Joint UNICEF, UNFPA and WHO Meeting with Manufacturers and Suppliers UN City, Copenhagen Presented by: Lama Suleiman 23 September 2014 Contracts
More informationGOODWILL INDUSTRIES OF COLORADO SPRINGS
GOODWILL INDUSTRIES OF COLORADO SPRINGS CORPORATE COMPLIANCE PROGRAM ADOPTED : By the Board of Directors Date: October 25, 2005 Attachment 2 Memorandum 10-41 TABLE OF CONTENTS Corporate Compliance Program
More informationIssued by: Executive Compliance Committee Prepared By: Chief Ethics & Compliance Officer Approved By: Board
Compliance Officer Vendor-Promotional Training and Business Associate- BACKGROUND The Office of Inspector General (OIG) has issued guidance regarding the development and implementation of compliance programs
More informationJOB DESCRIPTION AMNESTY INTERNATIONAL INTERNATIONAL SECRETARIAT (AIIS)
JOB DESCRIPTION AMNESTY INTERNATIONAL INTERNATIONAL SECRETARIAT (AIIS) JOB TITLE: Procurement Officer DEPARTMENT: Finance Department JOB PURPOSE: The Procurement Officer will support the Procurement &
More informationEmployee Handbook. Code of Conduct Acknowledgement
0 Employee Handbook Code of Conduct Acknowledgement A Message from Jay L. Geldmacher, Chief Executive Officer Dear Fellow Employee: The policy and historic practices of Artesyn Embedded Technologies have
More informationCODE OF CONDUCT AND ETHICS
CODE OF CONDUCT AND ETHICS As revised on November 16, 2017, Approved by the Corporate Compliance Committee on November 17, 2017, and Approved by the Board of Directors on December 11, 2017 A MESSAGE FROM
More informationGeneral Session: Review of the KL Principles A Voluntary Regional Approach Designed to Ensure Successful Code Adoption Mr.
General Session: Review of the KL Principles A Voluntary Regional Approach Designed to Ensure Successful Code Adoption Mr. Christopher White Co-Chair, APEC Expert Working Group to Develop an APEC Voluntary
More informationCODE OF CONDUCT Business ethics and compliance
CODE OF CONDUCT Business ethics and compliance BUSINESS PARTNERS Index FRESENIUS KABI BUSINESS PARTNER CODE OF CONDUCT 3 ABOUT US 4 FRESENIUS KABI S BUSINESS: CARING FOR LIFE FRESENIUS KABI S CORE VALUES
More informationEdison International. Supplier Code of Conduct
Edison International Supplier Code of Conduct For more than 125 years, Edison International Company (Edison), and its predecessor companies, have worked hard to earn and maintain the trust of our customers
More informationMV Transportation, Inc. Code of Conduct
MV Transportation, Inc. Code of Conduct This Code of Conduct ( Code ) has been adopted by the Board of Directors of MV Transportation, Inc. (the Company ) as the ethics and business code of conduct for
More informationBid Breakdown & Schedule FIRM SUBMITTING BID:
SECTION B ANDREW M. CUOMO Governor ALFONSO L. CARNEY, JR. Chair GERRARD P. BUSHELL President BID NO.: 609 PROJECT NAME & LOCATION: SUNY Broome 907 Front Street Binghmaton, New York Description: Furnish
More informationCPAs for NGOs Social Responsibility Programme
CPAs for NGOs Social Responsibility Programme Quick Guide Series Internal Control and Audit Introduction The Hong Kong Institute of CPAs has organized a series of CPAs for NGOs seminars to help local small-
More information