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AVOIDING CONFLICTS OF INTEREST
A conflict of interest occurs when an employee, trustee, or other agent acts in a manner that
| We report conflicts to the Office of the President or the NCBH Compliance Office. | puts other interests ahead of the interests of NCBH & Subsidiaries. We avoid situations that create a conflict of interest or the appearance of a conflict of interest. We report conflicts to the Office of the President or the NCBH Compliance Office. We demonstrate integrity when we follow these guidelines.
Nepotism: Family & Work
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We do not place or keep an employee in a position that has a direct or indirect reporting relationship to an immediate family member in accordance with Hospital policy.
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We do not use our influence at work to impact work decisions on behalf of ourselves, relatives, or friends.
Secondary Employment
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We ensure that any secondary employment, including employment with vendors and affiliates, does not impair or interfere with our job performance.
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We discuss the acceptance of secondary employment with our supervisors if we are uncertain of its acceptability.
Competing Fairly
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We market our services and products honestly, reflecting the services available and permitted by our licensure and accreditation.
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We compete fairly in the marketplace.
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We adhere to antitrust and trade regulations which encourage competition and fair trade practices.
Gifts, Entertainment & Gratuities
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We discourage accepting cash gifts in any amount. If a cash or cash-equivalent gift can not be grace- fully refused, it may be accepted on behalf of the entire unit/department or the Benevolence Fund. Any cash or cash-equivalent gift exceeding $100 should be directed to the Pastoral Care Department for the Benevolence Fund. Any cash or cash-equivalent gift accepted for a unit/department should be used for the benefit of the entire unit/department and reported to General Ledger Accounting.
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We report non-cash or cash-equivalent gifts or entertainment received from a single source by a unit/department exceeding $300 in total during a fiscal year to General Ledger Accounting.
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We do not accept any gifts that impair our ability to serve the best interest of the Hospital, subsidiaries, or affiliates. Any gifts or entertainment that might create a conflict of interest, that might appear to create a conflict of interest, or that exceed a nominal value (as defined in the Conflict of Interest Policy PPB-NCBH-BRD-02)—must be reported by electronic mail to: NCBHCompliance@wfubmc.edu or in writing to the Director of Internal Audit and Compliance.
Bribes, Kickbacks & Illegal Payments
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We do not accept, offer, solicit, or give commissions, bribes, kickbacks, inducements, or other inappropriate payments in any form.
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We do not pay for, or offer to pay for, patient admissions or referrals for service.
Political Activity
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We support our employees’ right to vote, but we do not seek to influence or direct employees to a particular position regarding political causes, parties, or candidates.
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We respect each employee’s right to choose whether or not to participate in political and community activities.
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We do not force co-workers or other NCBH & Subsidiaries constituencies to make a political contribution in time, money, or any other resource.
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We do not use NCBH & Subsidiaries resources to influence employees to vote for particular political parties or candidates and do not contribute resources to political parties, campaigns, or candidates.
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We may ask employees to support a specific issue that is in the best interest of NCBH & Subsidiaries by participating in letter writing campaigns.
Insider Relationships
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We neither purchase nor trade securities based on confidential and/or proprietary information obtained from NCBH & Subsidiaries, its customers, and vendors, nor give such information to others, including family members, for their benefit.
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We do not let relationships with vendors or suppliers influence formulary, product, or service acquisitions.
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We disclose conflicts of interest and do not take part in making any decisions affected by those conflicts.
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