Individual’s Responsibilities and
the Duty to Report
Every day we make a deliberate decision
to conduct business in a lawful and ethical
manner that reflects our values and our
culture. We expect all individuals to act
with integrity, think about their actions,
and speak up if they have a concern.
When facing a tough situation, consider
¡ Is it legal?
¡ Does my action reflect Healthfirst’s
¡ Does it reflect my responsibilities as
¡ Am I being truthful and honest with
¡ How might others be affected by the
choices I make?
¡ How would I feel if the situation was
¡ Have I raised questions and
concerns to my supervisor or
other company individuals?
If, after asking yourself these questions, you are still unsure of what to do or have
additional questions about the regulations, policies, or laws that govern your work, just
ask. The compliance hotline is confidential, and you may remain anonymous.
If you become aware of actual, suspected, or potential violations of the Code, of Healthfirst policies and procedures, or of federal, state, and local laws, you have an obligation to do the right thing and report your concerns.
Healthfirst may have an obligation to report concerns of noncompliance to the applicable governmental oversight agencies, and when necessary, refund overpayments.
Individuals will be subject to sanctions for failure to report suspected noncompliant activity or to participate in a compliance investigation.
Disciplinary action will be imposed on those who encourage, direct, facilitate, or permit
noncompliant behavior, among other activities. Compliance-related disciplinary
actions will be enforced fairly and consistently and will be commensurate
with the person’s involvement in the noncompliant activity.
Healthfirst offers several ways to anonymously report suspected
misconduct, ask questions, or raise concerns.
Your concerns will be taken seriously and promptly reviewed to determine if action is necessary.
We do not tolerate retaliation or intimidation by anyone—regardless
of their level or position—against an individual who has made a report in
good faith or who participates in an internal or external investigation.
A Message from Our CEO
Our Mission and Our Culture
Purpose and Scope of the Code
Responsibilities Our Workplace Our Relationships Our Business List of Policies
Referenced in the Code Compliance Program Oversight
OUR CORE RESPONSIBILITIES
Our success depends on our ability to overcome challenges better and faster than our competitors. To do this, individuals or “Affected Persons,” at all levels, must work together as a team, regardless of their function.
WHERE TO GO FOR MORE HELP
Confidential & Anonymous
Compliance Hotline: 1-877-879-9137
Confidential & Anonymous Website:
Chief Compliance Officer Jack Hackendorn:
Special Investigations Unit:
Where to Find Healthfirst Policies:
The Code of Conduct references company policies that are
listed in the back of this booklet and that can also be found
on the company’s Policies and Procedures Sharepoint site,
accessible via the Healthfirst intranet. The policies provide
additional detail and guidelines regarding expectations for
behavior, as set forth in this Code. All Healthfirst policies
on the Policies and Procedures Sharepoint site are
incorporated in this Code by reference.