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Code of Conduct

Index:
Purpose and Introduction
Principle 1: Legal Compliance
Principle 2: Business Ethics
Principle 3: Confidentiality
Principle 4: Conflicts of Interest
Principle 5: Business Relationships
Principle 6: Protection of Assets
Administration and Application of this Code of Conduct


Purpose

This Code of Conduct has been adopted by the University’s Board of Trustees on April 13, 2000 to provide standards by which trustees, officers, faculty, employees, agents and students of the University (hereinafter collectively referred to as “Members of the University Community”) will conduct themselves in order to protect and promote organization-wide integrity and to enhance the University’s ability to achieve the organization’s mission.

Introduction

The Code of Conduct contains Principles articulating the policy of the organization and Standards, which are intended to provide additional guidance to persons functioning in managerial or administrative capacities. The Principles set forth in this Code of Conduct shall be distributed periodically to all Members of the University Community. The Principles and Standards shall be distributed annually to trustees, officers, selected employees, agents and faculty having administrative or managerial responsibilities. All Members of the University Community are responsible to ensure that their behavior and activity is consistent with the Code of Conduct as well as University policies and procedures, and applicable federal, state and local laws and regulations, including Medicare and Medicaid requirements (hereinafter collectively referred to as “Applicable Rules”).

As used in this Code of Conduct, the term “The University” means the Philadelphia Health and Education Corporation d/b/a Drexel University Health Sciences University and each of its divisions, subsidiaries, and operating or business units. The “officer,” “faculty,” “trustee,” “employee,” “agent” and “student,” include any person who fills such a role or provides services on behalf of the University or any of its schools, divisions, subsidiaries, or operating or business units. The term “student” refers to all undergraduate and graduate students and research fellows enrolled in University programs in the study of medicine and other health care-related studies, and to all interns, residents and clinical fellows participating in graduate medical education programs.

Principle 1 - Legal Compliance

The University will strive to ensure that all activity by or on behalf of the organization is in compliance with Applicable Rules. The following Standards are intended to provide guidance to Members of the University Community to assist them in their obligation to comply with Applicable Rules. These standards are neither exclusive nor complete. Members of the University Community are required to comply with all Applicable Rules, whether or not specifically addressed in these policies. If questions arise regarding the existence, interpretation, or application of any law, they should be directed to the Chief Compliance Officer (“CCO”) or Office of General Counsel (“University Counsel”).

Standard 1.1 - Antitrust

All Members of the University Community must comply with applicable antitrust and similar laws which regulate competition. Examples of conduct prohibited by the laws include: (1) agreements to fix prices, bid rigging, and collusion (including price sharing) with competitors; (2) boycotts, certain exclusive dealing and price discrimination agreements; and (3) unfair trade practices including bribery, misappropriation of trade secrets, deception, intimidation, and similar unfair practices. Members of the University Community are expected to seek advice from the CCO or University Counsel when confronted with business decisions involving a risk of violation of the antitrust laws.

Standard 1.2 - Tax

As a nonprofit entity, the University has a legal and ethical obligation to act in compliance with applicable laws, to engage in activities in furtherance of its charitable purpose, and to ensure that its resources are used in a manner which furthers the public good rather than the private or personal interests of any individual. Consequently, the University and Members of the University Community will avoid compensation arrangements in excess of fair market value, will accurately report payments to appropriate taxing authorities, and will file all tax and information returns in a manner consistent with applicable laws.

Standard 1.3 - Fraud and Abuse

The University expects Members of the University Community to refrain from conduct which may violate the fraud and abuse laws. These laws prohibit: (1) direct, indirect or disguised payments in exchange for the referral of patients; (2) the submission of false, fraudulent or misleading claims to any government entity or third party payor, including claims for services not rendered, claims which characterize the service differently than the service actually rendered, or claims which do not otherwise comply with applicable program or contractual requirements; and (3) making false representations to any person or entity in order to gain or retain participation in a program or to obtain payment for any service. (For additional guidance, please refer to the various University Fraud and Abuse Compliance Policies.)

Standard 1.4 - Lobbying/Political Activity

The University expects each Member of the University Community to refrain from engaging in activity which may jeopardize the tax exempt status of the organization, including a variety of lobbying and political

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