Code of Conduct

Horizon has established the following “Code of Conduct” to guide all staff member, student, volunteer and consultant interactions with consumers, family members/significant others, referral sources, other care providers, vendors, suppliers, payers, the greater community, and one another. The overriding expectation is that all interactions are respectful and professional, and intended to be helpful and responsive.

Commitment to Consumers

1. I will not use my professional relationship with consumers or their families/significant others to further my own financial or personal interests, nor extend this relationship beyond appropriate professional limits.
2. I will not solicit, refer or admit current Horizon consumers to clinical services I provide privately or to an organization at which I am or will be employed, without prior authorization from my supervisor.
3. I will not threaten, coerce or intimidate, nor direct profane, abusive or disrespectful language towards consumers, their significant others or other Horizon customers.
4. I agree that a social or sexual relationship between a current or former consumer and myself is strictly prohibited, and will immediately inform my supervisor of the existence of any such relationship.
5. I will respect consumers’ confidentiality.
6. I will not discriminate against consumers for any reason, and will immediately report all instances of suspected discrimination or unprofessional conduct to my supervisor.

Commitment to Professionalism

1. I will utilize supervision to further my professional development and improve the quality of care I deliver.
2. I will report to my supervisor and seek assistance for any problem that impairs my professional performance.
3. I will keep my professional credentials current.
4. I will adhere to the regulations, standards and ethical guidelines promulgated by the pertinent government agencies, and by my professional association.
5. I will ensure that the clinical records or corporate documents that I am responsible for are accurate, complete and timely.

Commitment to Co-Workers

1. I will respect the rights and views of my colleagues, and treat them with honesty, fairness and courtesy.
2. I will strive to resolve differences of opinion with co-workers through cooperation and respect.
3. I will not discriminate against my co-workers for any reason, and will treat all co-workers with the utmost respect.
4. I will not sexually harass any employee, nor condone such harassment
5. I will not be disrespectful or insubordinate toward supervisors including the refusal to carry out directives, obey instructions, or to accept appropriate supervision.
6.  I will not threaten, coerce or intimidate, nor direct profane, abusive or disrespectful language towards my co-workers or supervisors.

Commitment to the Corporation

1. I will not falsify any Corporate or work-related documents.
2. I will not knowingly bill, or cause to bill, insurance companies, government agencies, grant organizations or other payors for any treatment or other corporate services that were not provided as described in the clinical record and billing invoice.
3. I will not leave my assigned place of work during scheduled hours without permission and without supervisory authorization, nor fail to report or return to work on time.
4. I will only use medications as prescribed and will not report to work if my ability to perform my job is impaired.
5. I will not use alcohol or other non-prescribed or illegal substances during the workday (including my lunch period), nor prior to my arrival for work.
6. I will not bring tobacco products or associated materials onto Horizon property, nor come to work, or return from lunch or breaks, with the odor of tobacco on my person.
7. I will not be careless or negligent of corporate materials, nor cause loss or damage to corporate property.
8. I will not share my computer password(s) with others, nor use corporate electronic communication equipment or other materials in violation of corporate policy.
9. I will not commit theft of corporate or other persons’ property.
10. I will not defame the reputation of the Corporation or any person associated with it.
11. I will not bring firearms, weapons, explosives or other potentially harmful materials on corporate premises.
12. I will not post or remove notices, signs, or any other forms of writing on bulletin boards or on Corporate property without proper authorization, and will not deface such materials.
13. I will adhere to all safety rules and procedures, and not create or contribute to unsanitary or unsafe conditions.
14. I will immediately report injuries and on-the-job accidents to my supervisor.
15. I will not sell or distribute any non-work related literature or products during work time or in work areas.
16. I will not solicit for any reason during work time except for corporate-related benefit.
17. I will not lobby for political candidates nor promote my personal political or spiritual/religious beliefs on corporate time or property.
18. I will not present myself as a representative of the Corporation, nor make public statements on behalf of the Corporation except as authorized.
19. I will make no contributions to political causes or parties using corporate funds or as a representative of the corporation.
20. I will not participate in the development of any agreement or contract on behalf of the corporation with a vendor, supplier, consultant, referral source or other provider with whom I have a personal or financial interest, without disclosing this interest to, at minimum, my supervisor and the Chief Compliance Officer.

Acceptance of Gifts

1. I will not solicit gifts from consumers, their family members/significant others, vendors, consultants, suppliers, referral sources or other providers except for corporate-approved purposes.
2. I will not accept personal gifts from these sources that are of more than nominal value.
3. I will not accept any gifts offered with the apparent intent to influence clinical decision-making or other actions of the Corporation.
4. I will use good judgment and discretion in accepting gifts and will share gifts received with other employees to the extent possible.
5. I understand that my attendance of vendor funded activities (meals, entertainment) requires that they have a corporate-related purpose.
6. I will not offer gifts with the intent of influencing the decision-making or actions of any purchaser, supplier, consumer, or government official towards the Corporation.

Confidentiality/Privacy

State and Federal law, and other regulations protect the confidentiality of all paper and electronic information regarding Horizon consumers, including their identity. There are civil and criminal penalties for the violation of laws and regulations regarding confidentiality. Horizon’s policies and procedures regarding the release of this protected health information are addressed in Horizon’s Privacy Policy within the Program Policy and Procedure Manual sections 181, 181a, and 181b. These sections are also on the corporate Intranet in the “Program Policy and Procedure” section.

How to Report a Possible Corporate Compliance Policy Violation

Horizon encourages staff to seek information regarding, and/or report all possible Corporate Compliance Policy violations to ensure our adherence with all applicable laws and regulations.

• Staff members are encouraged to seek information and assistance from their supervisor or any Senior Staff member regarding these matters, but are not required to do so.
• Staff members may make anonymous reports, but are encouraged to identify themselves in order to expedite the investigation.
• The Chief Compliance Officer will protect staff members who report violations from any retribution by supervisors or other staff with respect to promotions, assignments, compensation, or continued employment except in those cases in which it is determined that a report was made with malicious intent.

Staff members may report possible violations using any of the following methods:

1. Directly contacting Herb Weis, Ph.D., Horizon’s Chief Compliance Officer, at Administration by:
   • Phone (831-1800); or
   • Confidential voicemail (819-1830, mailbox 205); or
   • Letter (3020 Bailey Avenue, Buffalo 14215); or
   • E-Mail (hweis@horizon-health.org); or
   • By submitting a “Report of Possible Corporate Compliance Policy Violation” form that is available on the Corporate Intranet (Corporate Compliance/Privacy section).

   and/or

2. Directly contacting any member of senior management.

   and/or

3. Directly contacting Mr. Pete Grum, Chair of the Audit Committee at (716) 853-0802.

7/15/08