Code of Conduct
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This Code of Conduct and its related policies have been adopted to provide standards by which all members of the organization will conduct themselves. Individual conduct must be in a manner that protects and promotes organizational-wide integrity and enhances our ability to achieve our Mission. This Code is intended to serve as a guide to help our entire Mohawk Valley Network family make sound ethical decisions during day-to-day activities. This Code applies to all employees, medical staff members, vendors, contracted employees, consultants, students and volunteers. At times, the Code makes reference to ‘employee.’ This reference should be understood to include employees, medical staff members, vendors, contracted employees, consultants, students and volunteers. The Code is intended to be comprehensive and easily understood. In many cases, however, the subject requires additional guidance for those directly involved with a particular area. To provide additional guidance, we have developed a set of compliance policies that may be accessed on the Compliance Program site of the Faxton-St. Luke's Healthcare Intranet. These policies expand upon, or supplement, many of the principles discussed in this Code of Conduct.
Commitment to Ethical and Legal Conduct
Government regulation of the health care industry is increasingly complex. The federal government and New York State have made health care fraud and abuse a top enforcement priority. We take our responsibility to comply with laws and regulations very seriously. We ensure that we actively take steps to prevent and detect any violations of these laws and correct any violation that may be identified.
Fraud, Waste and Abuse
We have adopted policies to prevent and detect fraud, waste and abuse. This Code of Conduct and related Compliance Program outlines the intent of these policies. Our policies and various federal and state laws prohibit false claims and other fraudulent activity. Each employee, medical staff member, vendor, contracted employee, consultant, student and volunteer must adhere to the standards in this Code of Conduct and to the related polices addressed in the Compliance Program. Violations of these standards or policies can result in disciplinary measures, up to and including termination of employment. Violations may also result in civil actions and penalties.
Leadership Responsibilities
While all employees are obligated to follow our Code of Conduct and related policies, we expect our leaders to set the example and to be in every respect role models. We expect everyone in the organization with supervisory responsibility to exercise that responsibility in a manner that is thoughtful and respectful. We expect each supervisor to create an environment in which all staff are encouraged to raise concerns and propose ideas.
We also expect that our leaders will ensure staff has sufficient information to comply with laws, regulations and policies, as well as the resources to resolve ethical dilemmas. They must help to create a culture that promotes the highest standards of ethics and compliance. This culture must encourage everyone in the organization to share concerns when they arise. We must never sacrifice ethical and compliant behavior in the pursuit of business objectives.
Our continuous Leadership Education and Professional Development Program, coordinated through the Keith A. Fenstemacher Center for Continuous Learning, provides leaders with the fundamental principles and tools to engage in responsible leadership.
Questions About the Code of Conduct
After you have read the Code of Conduct and reviewed the related policies in the Compliance Program, you may have questions about how the standards apply to situations you may face. You may want to report a potential violation of company policy or violation of a federal or state regulation. You should always feel comfortable talking about your questions and concerns. There are several ways you can have your questions answered, even if you wish to ask them anonymously. You may address these questions with your supervisor or directly with a member of our compliance staff. You may also address your concerns through AlertLINE. Accessing the AlertLINE is easy, anonymous and confidential. This process is explained on page 17 of this Code of Conduct.
