Policy Manual sample

MDT Home Health Care Agency, Inc. Personal Business Transactions with MDT Home Health Care Agency, Inc.: A situation in which they directly or indirectly own, trade, or deal in real estate, materials, supplies, equipment or other property with the intent of selling, renting or contracting to MDT Home Health Care Agency, Inc.. In addition, no affected person shall simultaneously work as a consultant for MDT Home Health Care Agency, Inc. or otherwise be compensated by MDT Home Health Care Agency, Inc. for personal services. Certain Outside Roles and Commitments: A situation in which they serve as an officer, director, employee, committee member, advisor, agent, or representative or in any other professional activity capacity for any company, firm or business other than MDT Home Health Care Agency, Inc.. Employment of Relatives and Partner Relationships in the Workplace: MDT Home Health Care Agency, Inc. employees shall disclose any situation in which their relationship with a Family Member results in a potential, perceived or actual conflict of interest. A conflict of interest may be the result of a direct reporting relationship (e.g., a supervisory relationship) or an indirect reporting relationship (e.g., if one employee holds a position which may influence the status or compensation of a Family Member). Improper use of MDT Home Health Care Agency, Inc. resources for personal gain or the gain of another person. Employees may not use their position at MDT Home Health Care Agency, Inc. as the impetus to start a referral, service or supplies business that depends on MDT Home Health Care Agency, Inc. confidential information and/or specific operations knowledge obtained on the job at MDT Home Health Care Agency, Inc. or which utilizes MDT Home Health Care Agency, Inc. resources/facilities. Prohibition of Sharing Confidential Information regarding Agency practices, financial and business activities. Whenever an affected or interested person is in a position at MDT Home Health Care Agency, Inc. to gain confidential information regarding Agency practice/business/financial activities, the affected or interested person must not share that information with anyone outside of MDT Home Health Care Agency, Inc. and those without a need to know. A Duty to Disclose – Affected Persons 1. Disclosures Required upon Hire: All affected persons are required to complete the Conflict of Interest Disclosure as part of application process or named as Committee member. Human Resources will notify Administrators and Compliance Officers of new employees required to complete a disclosure form, that report any potential COI. 2. Annual Disclosures: All Governing Board members are required to complete the Conflict of Interest Disclosure Form on an annual basis for the duration of their service to MDT Home Health Care Agency, Inc. in a role covered by this policy. 3. Situational Disclosures: a. Any affected person, regardless of their position (administrators, employees, independent contractors, committee members), with an actual, perceived or potential conflict of interest must disclose such interest to his/her immediate supervisor as soon as the situation arises. 4. Conflicts evaluation and management: After disclosure of an actual, perceived or potential Home Health Agency Policies A-183