The Alegeus Business Partner Code of Conduct (the “Code”) outlines the operational, legal, and ethical expectations that Alegeus (the “Company”) has for all suppliers or vendors (“Vendors”) while conducting business with, or on behalf of, the Company. It applies to all entities that provide, or have provided, services to the Company, irrespective of contract, vendor designation, or renumeration status. Vendors are responsible for notifying all relevant downstream subcontractors of their obligations under this Code.
The integrity and honesty of our Vendors can impact the Company’s reputation. Therefore, the Company requires that its Vendors comply with this Code. This Code establishes clear guidance so that Vendors may conduct their business and provide services in a manner that aligns with the Company’s values and commitments. The Company expects that Vendors will uphold these standards in their own operations, in accordance with all applicable laws and regulations. All Vendors are expected to seek guidance from and raise concerns to the Company regarding any potential or actual violations of this code or of applicable law and regulation. Vendors must promptly report any known or suspected breach of this Code to the Company and fully cooperate with any subsequent investigation efforts. Alegeus reserves the right, per the underlying Vendor agreement, to investigate suspected violations of this Code.
This Code may be updated or amended from time to time. It is the responsibility of the Vendor to review it to ensure it is in compliance. To the extent there are any ambiguities or conflicts between the terms of any agreement entered into between a Vendor and the Company and the terms of this Code, the conflicting provisions of the agreement will prevail.
The Company is committed to operating under the highest ethical business practices and standards. It requires its Vendors to conduct their business in an ethical manner and with integrity. All Vendors must comply with the following standards and guidelines:
The Company does not tolerate bribery or corruption in any form. As such, Vendors will adhere to all rules and regulations regarding bribery, government officials, political contributions, gifts and entertainment, kickbacks and other improper benefits. While acting on the Company’s behalf, no Vendor may promise, offer, demand, give, or authorize bribes, kickbacks, improper benefits, or anything else of value that is intended (or could reasonably appear as intended) to be an improper reward for actions taken or an improper inducement that places another party under a future obligation.
Vendors will adhere to the Foreign Corrupt Practices Act (the “FCPA”) and all other applicable anti-bribery and anti-corruption (“ABAC”) laws including, but not limited to, the Prevention of Corruption Act (“POCA”) and the Prevention of Money Laundering Act (“PMLA”). Compliance with this Code requires that Vendors maintain effective policies and procedures to prevent and detect potential bribery and/or corruption, and to ensure compliance with all sections of this Code. Vendors must provide sufficient ABAC training to their employees, agents, and others acting on their behalf.
While acting on the Company’s behalf, no Vendor will provide any money or anything of value to any government official, political party, or any candidate for political office for the purposes of obtaining, retaining, or directing of business. Payments to government officials to expedite or ensure the performance of a routine governmental action or function (facilitation payments), are prohibited.
As long as no bid or purchasing decision is pending, Vendors may occasionally provide courtesy gifts of nominal value (e.g., pens, mugs, calendars) and entertainment to Company employees when such items are:
Notwithstanding the above, Vendors must not provide Company employees with any gifts of cash or cash equivalent (such as prepaid or gift cards). In addition, Vendors must not provide any Company personnel with any travel support, including overnight accommodations.
At least one Vendor representative must be present during any meal or entertainment that it provides to Company employees.
All transactions must be recorded accurately so that the purpose and amount of each transaction is clear. False or misleading records are not permitted. Vendors seeking exceptions must secure Company pre-approval.
Vendors will comply with all applicable anti-money laundering laws. Vendors will conduct appropriate due diligence on any vendors that will be used in the provision of Company services. Unusual requests, activities, and suspected violations must be investigated promptly and thoroughly. Confirmed violations will be reported to the Company’s Compliance Officer immediately.
Vendors are required to comply with all applicable trade laws and regulations when performing services for the Company. This obligation includes compliance with all applicable mandated trade embargoes and economic sanctions. Vendors will not cooperate with any foreign boycott that is prohibited by the United States.
A conflict of interest is any situation in which an entity or individual may have a personal interest or stand to gain a personal benefit in a manner that is or has the perception of being inconsistent with the best interests of the Company. Vendors may not engage in any activity that would cause or appear to cause such a conflict while conducting business with the Company or on its behalf. Any potential or actual conflicts of interest must be disclosed to the Company upon discovery. The Company will then review the conflict and respond accordingly.
Vendors are required to fully comply with all applicable health and safety laws, regulations, and standards. Vendors will take proactive measures that support accident prevention and minimize health risk exposure, including the provision of appropriate training and awareness to their personnel.
Vendors must comply with all applicable environmental regulations and are encouraged to conserve natural resources, avoid the use of hazardous materials, and engage in activities that reuse and recycle resources.
Vendors will share in the Company’s commitment to equal opportunity in the workplace and conduct their employment practices in full compliance with all applicable laws and regulations, and to treat their employees with dignity and respect.
Vendors will provide fair treatment and equal employment opportunities to employees and applicants for employment without regard to race, color, gender, gender identity, sexual orientation, religion, age, citizenship, national origin, disability, genetics, pregnancy, or service in the military. Vendors will comply with all applicable nondiscrimination laws and regulations and will appropriately address any alleged violations. Vendors must accommodate all disabilities to the extent required by law.
Vendors will maintain a workplace free of any physical or verbal abuse, threats, intimidation, unlawful discrimination, sexual harassment or any other form of harassment.
Vendors will not engage in or permit retaliation against any personnel who report potential misconduct, of any kind, in good faith.
The Company is committed to ensuring that the way it conducts its business and its dealings with Vendors reflects its values and prevents any form of modern slavery and human trafficking from occurring within its business and supply chain. As part of that effort, all Vendors must:
Vendors will conduct their business in full compliance with all applicable antitrust and fair competition laws. Vendors will not engage in or tolerate monopolization, price fixing, price discrimination, or other unfair trade practices in violation of applicable antitrust laws.
Vendors shall not trade in the securities (stock, option, etc.) of any other company if it has nonpublic material information about that company as a result of its work with the Company. Vendors will not disclose any non-public material information about the Company or any other companies which they have obtained as a result of their work with the Company or on its behalf.
The Company requires that its Vendors adhere to all applicable data and privacy laws and regulations. Vendors must have an information security and privacy program containing appropriate administrative, technical, and physical safeguards that are appropriate to the size and complexity of their operations, the nature and scope of the provided activities, and the personal information involved. Vendors must protect personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and all other forms of unlawful use or processing for as long as that information is retained.
To ensure that individuals’ privacy rights are protected, Vendors use and disclosure of personally identifiable information or protected health information must be limited to those purposes for which it was received. Neither personal nor confidential information may be transmitted to any location outside of the United States without the Company’s prior written consent.
The Company is committed to protecting its intellectual property assets and all other confidential and proprietary information. Any such information may be used only as required for the provision of agreed upon services to the Company. Vendors must comply with the Company’s intellectual property ownership rights and take all reasonable efforts and precautions to protect Company properties and assets that have been obtained as a result of their relationship with the Company. This requirement applies as long as Vendors maintain Company property and assets. Vendors will immediately return all such assets and confidential information upon termination of services.
Vendors are required to create and maintain accurate and timely financial books, records, and statements pertaining to their own business in accordance with applicable laws and regulations. Financial records submitted to the Company or created on the Company’s behalf must be accurate and complete and must comply with all applicable industry or professional standards. The Company forbids vendors from making any false, misleading, or incomplete entries. The disposal of any such records must be in full compliance with all applicable legal and regulatory requirements. Records that are relevant to any existing, pending, or anticipated regulatory investigation or legal proceeding must not be altered, destroyed, or concealed.
Vendors are required to screen or conduct other appropriate due diligence on its business partners, vendors, and Vendors, including to determine if they have been sanctioned by any government entity or are excluded from participation in any government programs.
Vendors may not speak on behalf of the Company unless explicitly authorized to do so. Vendors may not identify the Company nor comment on its relationship with the Company in any public communications without the Company’s prior written consent.
Vendors’ marketing and promotional materials and activities must conform to high ethical standards and comply with all applicable laws and regulations. Promotional materials and activities must fairly and accurately represent products and services. Use of the Company’s name or trademark and any representations of Company products or services is not permitted unless written authorization has been provided by the Company’s Legal Department.
Vendors shall not assign any personnel to provide services to the Company who are impaired by drug or alcohol use.
In carrying out duties for the Company, Vendors will not initiate, participate or assist in fraudulent or dishonest activities.
Vendors must comply with applicable statutory and regulatory law and all other requirements related to the administration, payment and delivery of Medicare benefits. Of particular importance, Vendors must comply with the requirements set forth in the Anti-Kickback Statute and False Claims Act. Vendors have the responsibility to identify and report potential Fraud, Waste, and Abuse activities. More specifically, Vendors are expressly prohibited from:
This Code of Conduct may be amended from time to time by the Company at its discretion. All updates are effective immediately on posting.