Code of Ethics and Business Conduct
This code of Ethics and Business Conduct ("Code") applies to all employees, officers and directors of DiaTri, LLC (collectively referred to as "employees"), including the affiliated companies of Midwest Diagnostic Management (MDM), Advanced Ancillary Services (AAS), and Diagnostic Benefit Management (DBM).
General Statement of Business Philosophy
The commitment to excellence is fundamental to the philosophy of DiaTri. We believe that good ethics and good business go together naturally to produce the very best long-term results for all of our employees.
Ethical business sits at the heart of DiaTri. It always has. It is part of who we are, our heritage, our processes and the way we behave.
Our business principles reflect and reinforce this. Through them, we will continue to play a positive part in the lives of our employees and our customers, as well as society in general. In addition, these principles will grow shareholder value, attract and develop the best kind of people, and most importantly create the highest level of service to our customers.
Purpose and Values
All employees work together to create a better way of managing diagnostic testing for patients and employees on a national level. This is our core purpose.
The measure of success is the value we create for our customers - both payors and providers. But we can only maximize this value if we honor our commitment to everyone of those customers as well as each other.
We are proud of our history and its relevance to how we continue to do business on a national scale. Our values inform what we stand for, how we behave and our approach to business and to management. In our daily actions we believe in showing integrity, openness and responsibility. This is reflected in the way we have built this company.
In the way we work we aim to honor those principles, have clear objectives and a quality organization.
Through this we can take advantage of change more rapidly, attract, hire and retain dedicated people and maintain an advantage over each of our competitors.
Legal Compliance
We are committed to strict compliance with the laws and regulations that apply to our business activities in every state in which we operate.
We are fully within the scope and compliance of HIPAA regulations.
Much Shelist serves as our legal counsel.
Ethical Business Practices
We expect honesty, integrity, openness and courtesy from all employees in their business dealings. This means that each employee must act in an ethical manner and respect the dignity and rights of other DiaTri colleagues and the people we do business with.
Communications
We communicate openly, directly and with precision with customers and each other. We will not provide special treatment to any one individual or business partner.
Material information about existing contracts and prospects is not to be divulged to competitors or outsiders.
Confidentiality
We fully expect employees to keep all company information confidential. This includes advertising and marketing plans, concepts and strategies, contracts with providers, customers, RFP's, financial information, personnel and employment matters, and other information that is not generally known to those outside of DiaTri. These obligations apply to all employees, including those who leave the company.
Fraud
We will not tolerate fraud of any kind against an employee or a customer.
Appropriate Use of Company Resources
We expect employees to use our resources in a responsible and ethical manner. Misuse is an ethical violation. For example, we support the use of e-mail and Internet services for conducting company business, but have standards and policies to protect the company from potential abuse and risk.
Competition
DiaTri and its employees are committed to open competition. We will compete aggressively but honestly, while complying with all regulations and laws wherever we conduct our business.
Employees
Communications
DiaTri encourages direct communication with employees. We believe this is the best way to obtain the complete participation of every employee's energy and points of view.
Pay, Benefits and Working Conditions
We respect each of our employee's rights in the workplace. We pay a fair wage according to the skills and performance with reference to industry compensation levels. We expect our employees to perform their duties in a manner that is fair and reasonable.
Health and Safety
We recognize the importance of maintaining a healthy and safe environment within our business. We seek to provide one according to local laws and regulations and building codes.
Equal Opportunities, Diversity and Personal Development
Our policy is that we recruit and promote employees on the basis of their suitability for the position without discriminating on grounds of race, color, ethnic or national origin, gender, sexual orientation, age, religion, marital status, or disability not related to the task. We do not and will not tolerate the sexual, physical or mental harassment of any DiaTri employee.
We value diversity and feel that employees from various backgrounds add to our company's culture and support the success of our organization. We also understand the value that all employees create for our business and will provide opportunities for personal and professional development.
Customers, Providers and Business Partners
We feel that we have an obligation to act in ways that will merit the trust, confidence and respect of those we conduct business with.
DiaTri's aim is to carry out our business honestly, ethically and with the highest respect for the rights and interests of those with whom we do business. We expect all of our business relationships to be mutually beneficial and will encourage our principles and standards be shared during the lifetime of those relationships.
Ethics Compliance
Application of Our Principles
This statement applies to all of our employees at DiaTri, which includes those specific to MDM, AAS, and DBM. It confirms our strong dedication to the highest standards of business conduct.
Each employee should use this document as a general guideline for behavior, particularly where no other standards apply. We also have a complete and comprehensive employee handbook, which can be referred to for further details.
DiaTri expects every employee to uphold our ethical business practices. Each manager and supervisor is responsible for the behavior of those under their direction. Failure to comply with the standards in this statement will result in disciplinary action, which may include termination of employment with DiaTri. Every effort must also be made to ensure that we promote these principles and values in all of our business affairs.
Speaking Up
If you know or have genuine suspicions of any legal violation in work-related issues or examples of violations contrary to these principles, you should report them to your manager or human resources department so that action can be taken.
We will make all reasonable efforts to protect the confidentiality of those who raise concerns. We will not criticize anyone reporting violations.
We will treat any attempt to prevent employees from raising concerns as a serious offense subject to disciplinary action.
Ensuring Compliance
These statements of business ethics and principles provide an overview of the principles that govern our business conduct.
This document should also speak to the minimum standards that should apply everywhere that we do business.
Human Resources will be responsible for making sure that:
- These principles are provided to all managers and supervisors within DiaTri and included as part of the overall employee handbook.
- Ensure that all new employees are made aware of, and adhere to these principles.
- Report any violations to the Ethics Officer for review by the Ethics Committee.
- At reasonable intervals, managers and supervisors confirm that they and those under their direction are in compliance with these principles.
No statement of business ethics can deal with all situations. It is the responsibility of all employees to apply these principles and exercise good judgment.