CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare...

28
Common Ground Code of Conduct

Transcript of CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare...

Page 1: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

Common GroundC o d e o f C o n d u c t

Page 2: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

Dear Employee:

At LifePoint Hospitals, we take pride in the fact that our hospitals share a vision — to provide high quality,accessible and compassionate health care to non-urban communities.

To make that vision a reality, each of us shares a commitment to the highest ethical and legal standards. Wecall this shared commitment “common ground.” Only upon common ground can we build the success of ourhospitals and our company.

The Code of Conduct included in this publication was developed to help guide us in our daily activities andinteractions with colleagues, patients, affiliated physicians and others with whom we work. We ask that youreview the Code carefully. Your understanding of it and commitment to it is crucial to our success.

Much of the Code’s content may seem second nature to you. This is understandable. In fact, we expect thatyou will not be surprised by these provisions. We depend on you to have your own personal code of ethicsthat will be responsive to the principles discussed in this Code. In many cases, the Code simply serves toreinforce our understanding of how we should conduct ourselves and our business.

Nevertheless, ours is a complex professional environment. Situations arise that are confusing. At one time oranother, you may have questions about ethical or legal issues. This Code contains information to help resolvethose issues. If you have further questions or you are faced with a situation that you believe is not consistentwith the Code, we urge you to consult immediately with your supervisor, another member of management atyour hospital, your local ethics and compliance officer, or the corporate ethics and compliance officer. You mayalso call the corporate ethics line at 1-877-508-LIFE (5433). We assure you that there will be no retribution forany inquiry or for reporting a possible breach of the Code.

You and every other LifePoint Hospitals employee play an important role in our future. We hope you will joinus in upholding our Code of Conduct. We know that together, standing on common ground, we can achieveour mission of Making Communities Healthier.

Sincerely,

William F. Carpenter III

Chief Executive Officer and Chairman of the Board

Copyright © 2007 LifePoint Asset Management Company, Inc. All rights reserved. This document is non-public and containsconfidential and proprietary information and trade secrets of LifePoint Asset Management Company, Inc. No part of this documentmay be reproduced, retransmitted or otherwise distributed in any form or by any means, electronic or mechanical, including byphotocopying, facsimile transmission, recording, re-keying or using any information storage and retrieval systems without the priorexpress written permission of LifePoint Asset Management Company, Inc.

Note: The terms “LifePoint,” “LifePoint Hospitals,” “Company” or “Organization” as used in this Code of Conduct refer to LifePointHospitals, Inc. and its affiliates, unless otherwise stated or indicated by context. The term "facilities" or "hospitals" refer to entitiesowned or operated by subsidiaries of LifePoint Hospitals, Inc. References to "LifePoint employees" or to "our employees" refer toemployees of subsidiaries of LifePoint Hospitals, Inc.

Page 3: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

Purpose of Our Code of Conduct ....................2LifePoint’s High Five..............................................2

Leadership Responsibilities .............................3

Our Fundamental Commitmentto Stakeholders .................................................3

Relationships With OurHealth Care Partners.........................................4

Patients...........................................................4Patient Care and Rights........................................4Emergency Treatment...........................................5Patient Information ..............................................5

Affiliated Physicians .....................................5

Third-Party Payors .........................................6Coding and Billing for Services............................6Cost Reports...........................................................6

Regulatory Compliance....................................7

Dealing With Accrediting Bodies ....................7

Business Information........................................8Accuracy, Retention and Disposalof Documents and Records ..................................8Confidential Information .....................................8Electronic Media....................................................9Financial Reporting and Records.........................9

Workplace Conduct and EmploymentPractices ...........................................................10Conflicts of Interest.............................................10Controlled Substances ........................................10Copyrights ............................................................10Diversity and Equal EmploymentOpportunity .........................................................10Harassment and Workplace Violence ...............10Health and Safety................................................11Hiring of Former and CurrentGovernment Employees .....................................11Inside Information and Securities Trading .......12License and Certification Renewals...................12Personal Use of LifePointHospitals’ Resources ............................................13

Relationships Among LifePointHospitals Employees............................................13Relationships With Subcontractors,Suppliers and Educational Institutions .............13Research ...............................................................14Substance Abuse and Mental Acuity ................14

Marketing Practices ........................................15Antitrust ...............................................................15Gathering Information About Competitors.....15Marketing and Advertising................................15

Environmental Compliance ...........................16

Business Courtesies ........................................17General .................................................................17Receiving Business Courtesies ............................17Extending Business Courtesies toNon-referral Sources ...........................................17Extending Business Courtesies toPossible Referral Sources ....................................18

Political Activities and Contributions ..........19

The Corporate Ethics and ComplianceProgram............................................................20Program Structure...............................................20Resources for Guidance andReporting Violations ...........................................20Confidentiality and Retaliation .........................20Personal Obligation to Report...........................21Internal Investigation of Reports ......................21Corrective Action.................................................21Discipline ..............................................................22Internal Audit and Other Monitoring ..............22Acknowledgment Process ..................................22

Acknowledgment............................................23

Special SectionsSeeking Help............................................................12Common Ground.....................................................14Notice to All Employees Regarding Fraud ...........22

Table of Contents

1

Page 4: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

Purpose of OurCode of ConductOur Code of Conduct provides guidance to allLifePoint Hospitals employees and assists us incarrying out our daily activities within appropriateethical and legal standards. These obligations applyto our relationships with patients, affiliatedphysicians, third-party payors, subcontractors,independent contractors, vendors, consultants andone another.

The Code is a critical component of our overallethics and compliance program. We developed theCode to ensure that we meet our ethical standardsand comply with applicable laws and regulations.

The Code is intended to be a statement that iscomprehensive and easily understood. In someinstances, the Code deals fully with the subjectcovered. In many cases, however, the subjectdiscussed has so much complexity that additionalguidance is necessary for those directly involvedwith the particular area to have sufficientdirection.

Though we promote the concept of localmanagement autonomy to meet local needs, thepolicies set forth in this Code are mandatory andmust be followed.

2

LifePoint’s High Five

At LifePoint Hospitals, we share a commonvision to provide high quality, accessible,compassionate and cost-effective health careto non-urban communities. To achieve this,we are committed to five core values:

Delivering High QualityPatient CareOur highest priority is caring for people —the friends, family and neighbors whom weserve in our communities.

Creating Excellent Workplacesfor our EmployeesWe are committed to providing employeeswith an environment based on respect andone that encourages personal andprofessional growth.

Supporting PhysiciansWe support physician practices by providinginnovative facilities, advanced technologyand a well-trained, organized clinical staff.

Providing Community ValueWe take pride in being a vital resource foreach community we serve. Most LifePointhospitals are the sole health care providersin their area and are actively involved intheir communities, supporting local civic andcharitable organizations.

Ensuring Fiscal ResponsibilityWe are fiscally responsible, ensuring that wemeet the capital needs of our hospitals andthe expectations of our stakeholders.

2

Page 5: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

While all LifePoint Hospitals employees areobligated to follow our Code, we expect ourleaders to set the example — to be in every respecta model. Leaders must ensure that those on theirteam have sufficient information to comply withlaw, regulation and policy, as well as the resourcesto resolve ethical dilemmas. They must help create

a culture within LifePoint that promotes thehighest standards of ethics and compliance. Thisculture must encourage everyone in theorganization to raise concerns when they arise. Wemust never sacrifice ethical and compliant behaviorin the pursuit of business objectives.

Leadership Responsibilities

3

We affirm the following commitments to LifePointHospitals stakeholders:

To our patients: We are committed to providinghigh quality care that is sensitive, compassionate,promptly delivered and cost-effective.

To our employees: We are committed toproviding a work setting that treats all employeeswith fairness, dignity and respect, and affordsthem an opportunity to grow, developprofessionally, and work in a team environment inwhich all ideas are considered.

To our affiliated physicians: We are committedto providing a work environment that hasexcellent facilities, modern equipment andoutstanding professional support.

To the communities we serve: We arecommitted to understanding the needs of thosecommunities and providing them with high quality,cost-effective health care. We realize that we as anorganization have a responsibility to help those inneed. We proudly support charitable contributionsand events in the communities we serve in aneffort to promote goodwill and further goodcauses.

To our shareholders: We are committed to thehighest standards of professional management,which we are certain can create unique efficienciesand innovative health care approaches and thusprovide favorable returns on our shareholders’investments over the long-term.

To our third-party payors: We are committed todealing with our third-party payors in a way thatdemonstrates our commitment to contractualobligations and reflects our shared concern forquality health care and bringing efficiency and costeffectiveness to health care. We encourage ourprivate third-party payors to adopt their own set ofcomparable ethical principles to recognize explicitlytheir obligations to patients, as well as the needfor fairness in dealing with providers.

To our regulators:We are committed to anenvironment in which compliance with rules,regulations and sound business practices is woveninto the corporate culture. We accept theresponsibility to aggressively self-govern andmonitor adherence to the requirements of law andto our Code of Conduct.

To our joint venture partners:We are committedto fully performing our responsibilities to manageany jointly owned facilities in a manner that reflectsthe mission and values of each organization.

To our suppliers: We are committed to faircompetition among prospective suppliers and thesense of responsibility required of a good customer.

To our volunteers: The concept of voluntaryassistance to the needs of patients and their familiesis an integral part of the fabric of health care. Weare committed to ensuring that our volunteers feela sense of meaningfulness from their volunteerwork and receive recognition for their volunteerefforts.

Our Fundamental Commitment to Stakeholders

Page 6: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

Relationships With Our Health Care Partners

4

P A T I E N T S

Patient Care and Rights

Our mission is to provide high quality health careto all of our patients. We treat all patients withrespect and dignity and provide care that is bothnecessary and appropriate. We make no distinctionin the admission, transfer or discharge of patientsor in the care we provide based on race, color,religion or national origin. Clinical care is based onidentified patient health care needs, not onpatient or organization economics.

Upon admission, each patient is provided with awritten statement of patient rights. This statementincludes the rights of the patient to make decisionsregarding medical care and conforms to allapplicable state and federal laws.

We assure patient involvement in all aspects oftheir care and obtain informed consent fortreatment. As applicable, each patient or patientrepresentative is provided with a clear explanationof care including, but not limited to, diagnosis,treatment plan, right to refuse or accept care, caredecision dilemmas, advance directive options,estimates of treatment costs, organ donation andprocurement, and an explanation of the risks andbenefits associated with available treatmentoptions. Patients have the right to request transfersto other hospitals. In such cases, the patient will begiven an explanation of the benefits, risks andalternatives.

Patients are informed of their right to makeadvance directives. Patient advance directives willbe honored within the limits of the law and theorganization’s mission, philosophy and capabilities.

Patients and their representatives will be accordedappropriate confidentiality, privacy, security andprotective services, opportunity for resolution ofcomplaints and pastoral counseling. Any

restrictions on a patient’s visitors, mail, telephoneor other communications must be evaluated fortheir therapeutic effectiveness and must be fullyexplained to and agreed upon by the patient orpatient representative. During prolonged stays inthe hospital, patients have the right to refuse toperform tasks in or for the hospital.

Patients are treated in a manner that preservestheir dignity, autonomy, self-esteem, civil rightsand involvement in their own care. LifePointHospitals employees receive training about patientrights in order to clearly understand their role insupporting them.

Compassion and care are part of our commitmentto the communities we serve. We strive to providehealth education, health promotion and illnessprevention programs as part of our efforts toimprove the quality of life of our patients and ourcommunities.

Page 7: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

5

Emergency Treatment

We follow the Emergency Medical Treatment AndLabor Act (EMTALA) in providing emergencymedical treatment to all patients, regardless oftheir ability to pay. Anyone with an emergencymedical condition is treated and admitted basedon medical necessity. In an emergency situation,financial and demographic information will beobtained only after the immediate needs of thepatient are met. We do not admit or dischargepatients simply on their ability to pay.

Patients will only be transferred to anotherhospital upon their request or if their medicalneeds cannot be met at the LifePoint hospital andappropriate care is knowingly available at anotherhospital. Patients will only be transferred after theyhave been stabilized within the capabilities andcapacity of the transferring hospital, and areformally accepted for treatment at the receivinghospital.

Patient Information

We collect information about the patient’s medicalcondition, history, medication and family illnessesto provide the best possible care. We realize thesensitive nature of this information and arecommitted to maintaining its confidentiality. Wedo not release or discuss patient-specificinformation with others unless it is necessary toserve the patient or authorized by law.

LifePoint Hospitals employees must never discloseconfidential information that violates the privacyrights of our patients. No LifePoint employee,affiliated physician or other health care partner hasa right to any patient information other than thatnecessary to perform his or her job.

Patients can expect that their privacy will beprotected and that patient-specific information willbe released only to persons authorized by law orby the patient’s written consent. In an emergencysituation, when requested by an institution or

physician then treating the patient, the patient’sspecific authorization is not required by law, butthe name of the institution and the personrequesting the information must be verified.

A F F I L I AT E D P H Y S I C I A N S

Any business arrangement with a physician mustbe structured to ensure precise compliance withlegal requirements. Such arrangements must be inwriting and approved by the Corporate Legaldepartment.

In order to ethically and legally meet all standardsregarding referrals and admissions, we will adherestrictly to two primary rules:

1.We do not pay for referrals.We accept patientreferrals and admissions based solely on thepatient’s clinical needs and our ability to renderthe needed services. We do not pay or offer to payanyone — employees, physicians or other persons— for referral of patients or to induce referrals.Violation of this policy has grave consequences forthe organization and the individuals involved,including civil and criminal penalties and possibleexclusion from participation in federally fundedhealth care programs.

2.We do not accept payments for referralsthat we make. No LifePoint Hospitals employeeor any other person acting on behalf of theorganization is permitted to solicit or receiveanything of value, directly or indirectly, inexchange for the referral of patients. Similarly,when making patient referrals to another healthcare provider, we do not take into account thevolume or value of referrals that the provider hasmade (or may make) to us.

All employees, medical staff members and privilegedpractitioners should immediately report violations orsuspected violations to a supervisor or member ofmanagement, the local ethics and complianceofficer, the corporate ethics line or the corporateethics and compliance officer.

Relationships With Our Health Care Partners cont.

Page 8: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

T H I R D - PA R T Y PAY O R S

Coding and Billing for Services

We will take great care to ensure that all billings togovernmental and other payors reflect truth andaccuracy and conform to all pertinent federal andstate laws and regulations.

We prohibit any employee or agent of LifePointHospitals from knowingly presenting or causing tobe presented claims for payment or approval thatare false, fictitious or fraudulent.

We will operate oversight systems designed toverify that claims are submitted only for servicesactually provided and that services are billed asprovided. These systems will emphasize the criticalnature of complete and accurate documentation ofservices provided. As part of our documentationeffort, we will maintain current and accuratemedical records.

Any subcontractors engaged to perform billing orcoding services must have the necessary skills,quality assurance processes, systems andappropriate procedures to ensure that all billingsfor governmental and other payors are accurateand complete. LifePoint prefers to contract withsuch entities that have adopted their own ethicsand compliance programs. Third-party billingentities, contractors and preferred vendors that weconsider must be approved consistent with ourcorporate policy on this subject.

For coding questions, contact the 3M Nosology lineat 1-800-537-1666. For questions concerning billingissues, contact your local business office director.

Cost Reports

Our business involves reimbursement undergovernment programs that require the submissionof certain reports of our costs of operation. We willcomply with federal and state laws relating to allcost reports. These laws and regulations definewhich costs are allowable and outline theappropriate methodologies to claim reimbursementfor the cost of services provided to programbeneficiaries. Given their complexity, all issuesrelated to the completion and settlement of costreports must be communicated through orcoordinated with our Reimbursement department.

6

Relationships With Our Health Care Partners cont.

Page 9: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

7

Hospitals affiliated with LifePoint Hospitals providevaried health care services in many states. Theseservices generally may be provided only pursuantto appropriate federal, state and local laws andregulations. Such laws and regulations may includesubjects such as certificates of need, licenses,permits, accreditation, access to treatment, consentto treatment, medical record keeping, access tomedical records and confidentiality, patients’ rights,terminal care decision-making, medical staffmembership and clinical privileges, corporatepractice of medicine restrictions, and Medicare andMedicaid regulations. The organization is subject tonumerous other laws in addition to these healthcare regulations.

We will comply with all applicable laws andregulations. All employees, medical staff members,privileged practitioners and contract serviceproviders must be knowledgeable about andensure compliance with all laws and regulationsand should immediately report violations orsuspected violations to a supervisor or member ofmanagement, the local ethics and complianceofficer, the corporate ethics line or the corporateethics and compliance officer.

LifePoint will be forthright in dealing with anybilling inquiries. Requests for information will beanswered with complete, factual and accurate

information. We will cooperate with and becourteous to all government inspectors and providethem with the information to which they areentitled during an inspection.

During a government inspection, you must neverconceal, destroy or alter any documents, lie ormake misleading statements to governmentrepresentatives. You should not influence anotheremployee to provide inaccurate information orobstruct, mislead or delay the communication ofinformation or records relating to a possibleviolation of law.

In order to ensure that we fully meet all regulatoryobligations, LifePoint Hospitals employees andaffiliated physicians must be informed about statedareas of potential compliance concern. TheDepartment of Health and Human Services, andparticularly its inspector general, has routinelynotified health care providers of areas in which itbelieves that insufficient attention is being given togovernment regulations. We should be diligent infollowing such guidance and reviewingappropriate elements of our system to ensure theircorrectness.

LifePoint Hospitals will provide its employees withthe information and education they need tocomply fully with all applicable laws andregulations.

Regulatory Compliance

LifePoint Hospitals will deal with all accreditingbodies in a direct, open and honest manner. Noaction should ever be taken in relationships withaccrediting bodies that would mislead theaccreditor or its survey teams, either directly orindirectly. Where LifePoint determines to seek anyform of accreditation, all standards of theaccrediting group are important and must befollowed.

The scope of matters related to accreditation ofvarious bodies extends beyond the scope of thisCode of Conduct. The purpose of our Code ofConduct is to provide general guidance on subjectsof wide interest within the organization.

Dealing With Accrediting Bodies

Page 10: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

Business InformationAccuracy, Retention and Disposalof Documents and Records

Each LifePoint Hospitals employee is responsiblefor the integrity and accuracy of our organization’sdocuments and records, not only to comply withregulatory and legal requirements but also toensure that records are available to defend ourbusiness practices and actions. No one may alter orfalsify information on any record or document.

Medical and business documents and records areretained in accordance with the law and ourrecord retention policy. Medical and businessdocuments include paper documents such as lettersand memos, computer-based information such ase-mail or computer files on disk or tape, and anyother medium that contains information about theorganization or its business activities. It isimportant to retain and destroy recordsappropriately according to our policy. You mustnot tamper with records or remove or destroythem prior to the date specified in company policyfor such action.

Confidential Information

Confidential information about our organization’sstrategies and operations is a valuable asset.Although you may use our confidentialinformation to perform your job, you must notshare this information with others outside ofLifePoint Hospitals or your department unless youare doing so within the scope of your jobresponsibilities, and the person to whom youintend to disclose the information has a legitimatebusiness need to know this information. Violationof this policy may subject an employee totermination and other legal action.

As a condition of your employment with LifePointHospitals, you will not seek to benefit personally orpermit others to benefit through the use ordisclosure of our confidential information. Yourobligations are not limited to documents andmaterials that are specifically marked as“confidential.” If, however, a document is expresslymarked as “confidential,” you are expected tofollow all instructions noted on such documentpertaining to the photocopying, transmitting ordisclosing of any information contained therein.Examples of confidential information includepersonnel data maintained by the organization,patient lists and clinical information, pricing andcost data, information pertaining to acquisitions,divestitures, affiliations and mergers, financialdata, research data, strategic plans, marketingstrategies, techniques, employee lists, supplier andsubcontractor information, training materials,proprietary computer software and otherinformation not generally known by the public.

This provision does not restrict the right of anemployee to disclose, if he or she wishes,information about his or her own compensation,benefits or terms and conditions of employment.

8

Page 11: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

Electronic Media

All communications systems, electronic mail,intranet, Internet access or voicemail are theproperty of the organization and are to beprimarily used for business purposes. Highly limitedreasonable personal use of LifePoint Hospitals’communications systems is permitted; however,you should assume that these communications arenot private. Patient or confidential informationshould not be sent through the intranet or theInternet unless security measures are in place thatassure confidentiality.

LifePoint reserves the right to periodically access,monitor and disclose the contents of the intranet,e-mail and voicemail messages. Access anddisclosure of individual employee messages mayonly be done with the approval of the CorporateLegal department.

Employees may not use internal communicationchannels or access the Internet at work to post,store, transmit, download or distribute anythreatening, knowingly reckless, maliciously falseor obscene materials. This prohibition includesanything constituting or encouraging a criminaloffense, giving rise to civil liability or otherwiseviolating any laws. Additionally, these channels ofcommunication may not be used to send chainletters, personal broadcast messages orcopyrighted documents that are not authorized forreproduction, nor are they to be used to conduct ajob search or open misaddressed mail.

Employees may not install personal software onLifePoint computer equipment, and LifePoint-owned software may not be installed onemployees’ personal computers. While there areexceptions, there are very few. Please contact yourlocal director of information systems or refer to theLifePoint PC Software License Management policyfor more details.

Employees who abuse our communications systemsor use them excessively for non-business purposesmay lose these privileges and be subject todisciplinary action.

Financial Reporting and Records

We have established and maintain a high standardof accuracy and completeness in thedocumentation and reporting of all financialrecords. These records serve as a basis formanaging our business and are important inmeeting our obligations to patients, employees,shareholders, suppliers and others. They are alsonecessary for compliance with tax and financialreporting requirements.

All financial information must reflect actualtransactions and conform to generally acceptedaccounting principles. No undisclosed orunrecorded funds or assets may be established.

LifePoint Hospitals maintains a system of internalcontrols to provide reasonable assurances that alltransactions are executed in accordance withmanagement’s authorization and are recorded in aproper manner so as to maintain accountability ofthe organization’s assets.

Business Information cont.

9

Page 12: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

10

Workplace Conduct and Employment PracticesConflicts of Interest

A conflict of interest may exist if your outsideactivities or personal interests influence or appearto influence your ability to make objectivedecisions in the course of your job responsibilities.A conflict of interest may also exist if the demandsof any outside activities hinder or distract you fromthe performance of your job or cause you to useLifePoint Hospitals’ resources for non-Lifepointpurposes. It is your obligation to ensure that yourinterests remain free of conflicts in theperformance of your responsibilities at LifePoint. Ifyou have any question about whether an outsideactivity might constitute a conflict of interest, youmust obtain the approval of your supervisor beforepursuing the activity.

Controlled Substances

Some of our employees routinely have access toprescription drugs, controlled substances and othermedical supplies. Many of these substances aregoverned and monitored by specific regulatoryorganizations and must be administered byphysician order only. It is extremely important thatthese items be handled properly and only byauthorized individuals to minimize risks toLifePoint and to patients. If you become aware ofthe diversion of drugs from the organization, youshould report the incident immediately.

Copyrights

LifePoint Hospitals employees may only makecopies of copyrighted materials pursuant to theorganization’s policy on such matters.

Diversity and Equal EmploymentOpportunity

Our employees provide us with a widecomplement of talents that contribute greatly toour success. We are committed to providing anequal opportunity work environment whereeveryone is treated with fairness, dignity andrespect. We will comply with all laws, regulationsand policies related to non-discrimination in all ofour personnel actions. Such actions include hiring,staff reductions, transfers, terminations,evaluations, recruiting, compensation, correctiveaction, discipline and promotions.

No one may discriminate against any individualwith a disability with respect to any offer, term orcondition of employment. We will makereasonable accommodations to the known physicaland mental limitations of otherwise qualifiedindividuals with disabilities.

Harassment and WorkplaceViolence

Each LifePoint Hospitals employee has the right towork in an environment free of harassment. Wewill not tolerate harassment by anyone based onthe diverse characteristics or cultural backgroundsof those who work with us. Degrading orhumiliating jokes, slurs, intimidation or otherharassing conduct is not acceptable in ourworkplace.

Any form of sexual harassment is strictlyprohibited. This includes unwelcome sexualadvances or requests for sexual favors inconjunction with employment decisions. Moreover,verbal or physical conduct of a sexual nature thatinterferes with an individual’s work performance orcreates an intimidating, hostile or offensive workenvironment has no place at LifePoint Hospitals.

Page 13: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

11

Harassment also includes incidents of workplaceviolence. Workplace violence includes robbery andother commercial crimes, stalking cases, violencedirected at the employer, terrorism and hate crimescommitted by current or former employees. As partof our commitment to providing a safe workplacefor our employees and physicians, we prohibitpossession of firearms, other weapons, explosivedevices or other dangerous materials on LifePointpremises. Employees who observe or experienceany form of harassment or violence should reportthe incident to their supervisor, the HumanResources department, a member of management,their local ethics and compliance officer, thecorporate ethics line or the corporate ethics andcompliance officer.

Health and Safety

All LifePoint Hospitals facilities must comply withall government regulations and rules and withLifePoint policies or required facility practices thatpromote the protection of workplace health andsafety. Our policies have been developed to protectyou from potential workplace hazards. You shouldbecome familiar with and understand how thesepolicies apply to your specific job responsibilities,and seek advice from your supervisor or the safetyofficer whenever you have a question or concern.It is important for you to advise your supervisor orthe safety officer of any serious workplace injury orany situation presenting a danger of injury so thattimely corrective action may be taken to resolvethe issue.

Hiring of Former and CurrentGovernment Employees

The recruitment and employment of former orcurrent U.S. government employees is subject tocomplex rules that change frequently and vary byemployee. Similar rules may also apply to currentor former state or local government employees orlegislators and members of their immediatefamilies.

If a former government employee or consultantwishes to become employed by (or a consultant to)LifePoint Hospitals, care should be exercised toensure that the requirements of conflict of interestlaws are not violated. Each situation should beconsidered on an individual basis and you shouldconsult with the Corporate Human Resources orCorporate Legal departments on issues related torecruitment and hiring of former or currentgovernment employees.

Workplace Conduct and Employment Practices cont.

Page 14: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

Inside Information and SecuritiesTrading

In the course of your employment, you maybecome aware of non-public information aboutLifePoint Hospitals that may be material to aninvestor’s decision to buy or sell the organization’ssecurities. Non-public, material information mayinclude plans for mergers, marketing strategy,financial results or other business dealings. Youmay not discuss this type of information withanyone outside of the organization. Within theorganization, you should discuss this informationon a strictly “need to know” basis only with otherswho require this information to perform their jobs.

Securities law and LifePoint policy prohibitindividuals from trading in the marketablesecurities of a publicly held organization orinfluencing others to trade in such securities on thebasis of non-public, material information. Theserestrictions are meant to ensure that the generalpublic has complete and timely information onwhich to base investment decisions.

If you obtain access to non-public, materialinformation about the organization whileperforming your job, you may not use thatinformation to buy, sell or retain securities ofLifePoint or any other company. Even if you do notbuy or sell securities based on what you know,discussing the information with others such asfamily members, friends, vendors, suppliers andother outside acquaintances is prohibited until theinformation is considered to be public. Informationis considered to be public three days after ageneral release of the information to the media.

License and Certification Renewals

Employees and individuals retained as independentcontractors in positions that require professionallicenses, certifications or other credentials areresponsible for maintaining the current status oftheir credentials and shall comply at all times withfederal and state requirements applicable to theirrespective disciplines. To ensure compliance,LifePoint Hospitals may require evidence of theindividual having a current license or credentialstatus.

LifePoint Hospitals will not allow any employee orindependent contractor to work without valid,current licenses or credentials.

Workplace Conduct and Employment Practices cont.

12

Seeking Help

For help with an ethics or compliance issueor to report a possible violation of the Codeof Conduct, contact your supervisor, anothermember of local management, your localethics and compliance officer, the corporateethics and compliance officer, or thecorporate ethics line at: 1-877-508-LIFE(5433).

For assistance with coding questions, call:1-800-537-1666.

Page 15: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

13

Personal Use of LifePoint Hospitals’Resources

It is the responsibility of each LifePoint Hospitalsemployee and/or physician to preserve ourorganization’s assets including time, materials,supplies, equipment and information. Organizationassets are to be maintained for business-relatedpurposes. As a general rule, the personal use ofany LifePoint asset without the prior approval ofyour supervisor is prohibited.

The occasional use of items such as copyingfacilities or telephones, where the cost to LifePointis insignificant, is permissible. Any community orcharitable use of organization resources must beapproved in advance by your supervisor. Any use oforganization resources for personal financial gainunrelated to LifePoint business is prohibited.

Relationships Among LifePointHospitals Employees

In the normal day-to-day functions of anorganization like LifePoint Hospitals, there areissues that arise that relate to how people in theorganization deal with one another. It is impossibleto foresee all of these, and many do not requireexplicit treatment in a document like this. A few,however, routinely arise.

One involves gift giving among employees and/orphysicians for certain occasions. While we wish toavoid any strict rules, no one should ever feelcompelled to give a gift to anyone, and any giftsoffered or received should be appropriate to thecircumstances. A lavish gift to anyone in asupervisory role would clearly violate organizationpolicy.

Another situation that routinely arises is fund-raising or similar efforts. No one should ever bemade to feel compelled to participate in any fund-raising or charitable efforts.

Relationships With Subcontractors,Suppliers and EducationalInstitutions

We must manage our subcontractor and supplierrelationships in a fair and reasonable manner,consistent with all applicable laws and goodbusiness practices. We promote competitiveprocurement to the maximum extent practicable.Our selection of subcontractors, suppliers andvendors will be made on the basis of objectivecriteria including quality, technical excellence,price, delivery, adherence to schedules, service andmaintenance of adequate sources of supply.

Our purchasing decisions will be made on thesupplier’s ability to meet our needs and not onpersonal relationships and friendships. We willalways employ the highest ethical standards inbusiness practices in source selection, negotiation,determination of contract awards and theadministration of all purchasing activities. We willnot communicate to a third party confidentialinformation given to us by our suppliers unlessdirected in writing to do so by the supplier. We willnot disclose contract pricing and information toany outside parties. (The subject of businesscourtesies, which might be offered bysubcontractors or suppliers, is discussed later inthis Code.)

All hospitals having a relationship with aneducational institution must have a writtenagreement that defines both parties’ roles and thehospital’s retention of the responsibility for thequality of patient care.

Workplace Conduct and Employment Practices cont.

Page 16: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

14

Research

We follow high ethical standards and all legalrequirements in any research conducted by ourphysicians and professional staff. We do nottolerate intentional research misconduct. Researchmisconduct includes making up, changing orcopying results from other studies withoutperforming the research.

All patients asked to participate in a researchproject are given a full explanation of alternativeservices that might prove beneficial to them. Theyare also fully informed of potential discomfortsand are given a full explanation of the risks,expected benefits and alternatives. The patientsare fully informed of the procedures to befollowed, especially those that are experimental innature. Refusal of a patient to participate in aresearch study will not compromise their access toservices.

All personnel applying for or performing researchof any type are responsible for maintaining thehighest ethical standards in any written or oralcommunications regarding their research projects,as well as following appropriate legal and researchguidelines. As in all accounting and financial recordkeeping, our policy is to submit only true, accurateand complete costs related to research grants.

Substance Abuse and MentalAcuity

To protect the interests of our employees,physicians and patients, we are committed to analcohol- and drug-free work environment. Allemployees and physicians must report for workfree of the influence of alcohol and illegal drugs.Reporting to work under the influence of any

illegal drug or alcohol, having an illegal drug inyour system, or using, possessing or selling illegaldrugs while on LifePoint Hospitals’ work time orproperty may result in immediate termination. Wemay use drug testing as a means of enforcing thispolicy.

It is also recognized that individuals may be takingprescription drugs that could impair judgment orother skills required in job performance. If youhave questions about the effect of such medicationon your performance, consult with your supervisor.

Workplace Conduct and Employment Practices cont.

Common Ground

If you are faced with an ethical orcompliance issue:

Consider the facts and how the situationaffects stakeholders.

Observe the policies, procedures, laws andregulations outlined in the Code of Conduct.Also consider your own values. What appliesto this situation?

Measure your alternatives for resolving thesituation.

Make a decision about the best course ofaction.

Organize your thoughts and ask yourselfonce more: Is this the right thing to do? Domy actions support our Code of Conduct?

Notify management in a timely manner.

Page 17: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

15

Antitrust

Antitrust laws are designed to create a levelplaying field in the marketplace and to promotefair competition. These laws could be violated bydiscussing LifePoint Hospitals’ business with acompetitor, such as how our prices are set,disclosing the terms of supplier relationships,allocating markets among competitors or agreeingwith a competitor to refuse to deal with a supplier.Our competitors are other health systems andfacilities in markets where we operate.

At trade association meetings, be alert to potentialsituations where it may not be appropriate for youto participate in discussions regarding prohibitedsubjects with our competitors. Prohibited subjectsinclude any aspect of pricing, our services in themarket, key costs such as labor costs, andmarketing plans. If a competitor raises a prohibitedsubject, end the conversation immediately.Document your refusal to participate in theconversation by requesting that your objection bereflected in the meeting minutes and notify theCorporate Legal department of the incident.

In general, avoid discussing sensitive topics withcompetitors or suppliers unless you are proceedingwith the advice of the Corporate Legaldepartment.

You must also not provide any information inresponse to oral or written inquiry concerning anantitrust matter without first consulting theCorporate Legal department.

Gathering Information AboutCompetitors

It is not unusual to obtain information about otherorganizations, including our competitors, throughlegal and ethical means such as public documents,public presentations, journal and magazine articles,and other published and spoken information.However, it is not acceptable for you to obtainproprietary or confidential information about acompetitor through illegal means. It is also notacceptable to seek proprietary or confidentialinformation when doing so would require anyoneto violate a contractual agreement, such as aconfidentiality agreement with a prior employer.

Marketing and Advertising

We may use marketing and advertising activities toeducate the public, provide information to thecommunity, increase awareness of our services andrecruit employees. We will present only truthful,fully informative and non-deceptive information inthese materials and announcements. All marketingmaterials will appropriately reflect the level ofservices available.

Marketing Practices

Page 18: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

16

It is our policy to comply with all environmentallaws and regulations as they relate to LifePointHospitals’ operations. We will act to preserve ournatural resources to the fullest extent reasonablypossible. We will comply with all environmentallaws and operate each of our facilities with thenecessary permits, approvals and controls. We willdiligently employ proper procedures with respectto handling and disposal of hazardous andbiohazardous waste, including medical waste.

In helping LifePoint comply with these laws andregulations, you must understand how job dutiesmay impact the environment, adhere to allrequirements for the proper handling of hazardousmaterials, and immediately alert your supervisor ofany situation regarding the discharge of ahazardous substance, improper disposal of medicalwaste or any situation that may be potentiallydamaging to the environment.

Environmental Compliance

Page 19: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

17

General

Nothing in this part of the Code of Conduct shouldbe considered in any way as an encouragement tomake, solicit or receive any type of entertainmentor gift. For clarity purposes, note that theselimitations govern activities with those outside ofLifePoint Hospitals. This section does not pertain toactions between the organization and itsemployees nor actions among LifePoint employeesthemselves.

Receiving Business Courtesies

We recognize that there will be times when youmay wish to accept, from a current or potentialbusiness associate, an invitation to attend a socialevent in order to further develop your businessrelationship. These events must not includeexpenses paid for any travel costs (other than in avehicle owned privately or by the host company) orovernight lodging. The cost associated with suchan event must be reasonable and appropriate. As ageneral guideline, this means that the cost will notexceed $100.00 per person.

Sometimes a business associate will extend trainingand educational opportunities that include traveland overnight accommodations to you at no costto you or LifePoint Hospitals. Similarly, there aresome circumstances in which you are invited to anevent at a vendor’s expense to receive informationabout new products or services. Prior to acceptingany such invitation, you must receive approval todo so consistent with the corporate policy on thissubject.

As a LifePoint employee, you may accept gifts witha total value of $50.00 or less in any one year fromany individual or organization who has a businessrelationship with LifePoint. For purposes of thisparagraph, physicians practicing in LifePoint’s

hospitals are considered to have such arelationship. Perishable or consumable gifts givento a department or group are not subject to anyspecific limitation. You may never accept cash orfinancial instruments (e.g., checks, stocks). Finally,under no circumstances may you solicit a gift.

Extending Business Courtesies toNon-referral Sources

No portion of this section applies to any individualwho makes, or is in a position to make, referrals toa LifePoint hospital.

There may be times when you wish to extend to acurrent or potential business associate (other thansomeone who may be in a position to make apatient referral) an invitation to attend a socialevent in order to further develop your businessrelationship. The purpose of the entertainmentmust never be to induce any favorable businessaction. During these events, topics of a businessnature must be discussed and the host must bepresent. These events must not include expensespaid for any travel costs (other than in a vehicleowned privately or by the host entity) or overnightlodging. The cost associated with such an eventmust be reasonable and appropriate. As a generalguideline, this means that the cost will not exceed$100.00 per person.

Business Courtesies

Page 20: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

18

With regard to the $100.00 guideline, if youanticipate an event will exceed the $100.00guideline or if circumstances arise where anentertainment event was contemplated prior tothe event to meet the guideline but unforeseeablyexceeded it, corporate policy on this subject mustbe followed. LifePoint Hospitals will under nocircumstances sanction participation in anybusiness entertainment that might be consideredlavish.

Also, LifePoint’s hospitals may routinely sponsorevents with a legitimate business purpose.Provided that such events are for businesspurposes, reasonable and appropriate meals andentertainment may be offered. In addition,transportation and lodging can be offered.However, all elements of such events, includingthese courtesy elements, must be consistent withthe corporate policy on such events.

It is critical to avoid the appearance of improprietywhen giving gifts to individuals who do business orwho are seeking to do business with LifePointHospitals. We will never use gifts or otherincentives to improperly influence relationships orbusiness outcomes. Gifts to business associates whoare not government employees must not exceed$50.00 per year per recipient. You may never givecash or financial instuments (e.g., stocks, checks).The corporate policy on business courtesies mayfrom time to time provide modest flexibility inorder to permit appropriate recognition of theefforts of those who have spent meaningfulamounts of volunteer time on behalf of LifePointHospitals.

U.S. federal and state governments have strict rulesand laws regarding gifts, meals and other businesscourtesies for their employees. LifePoint’s policy isto not provide any gifts, entertainment, meals oranything else of value to any employee of theexecutive branch of the federal government,

except for minor refreshments in connection withbusiness discussions or promotional items with theLifePoint Hospitals or hospital logo valued at nomore than $10.00.

With regard to gifts, meals and other businesscourtesies involving any other category ofgovernment official or employee, you mustdetermine the particular rules applying to any suchperson and carefully follow them.

Extending Business Courtesies toPossible Referral Sources

Any entertainment or gift involving physicians orother persons who are in a position to referpatients to our health care facilities must beundertaken in accordance with corporate policies.We will comply with all federal laws, rules andregulations regarding these practices.

Business Courtesies cont.

Page 21: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

19

LifePoint Hospitals’ political participation is limitedby law. LifePoint’s funds or resources are not to beused to contribute directly to political campaignsor for gifts or payments to any political party orany of their affiliated organizations. Organizationresources include financial and non-financialdonations such as using work time and telephonesto solicit for a political cause or candidate or theloaning of LifePoint property for use in thepolitical campaign. LifePoint operates a federalPolitical Action Committee (PAC) that is fundedsolely through individual contributions. Wherepermitted by law, LifePoint may choose tocontribute to a particular state PAC or StateHospital Association PAC. The conduct of anypolitical action committee is to be consistent withrelevant laws, regulations and internal policies.

It is important to separate personal and corporatepolitical activities in order to comply with theappropriate rules and regulations relating tolobbying or attemptingto influencegovernment officials.You may, of course,participate in thepolitical process onyour own time and atyour own expense.While you are doing so,it is important not togive the impressionthat you are speakingon behalf of orrepresenting LifePointHospitals in theseactivities. You cannotseek to be reimbursedby LifePoint for anypersonal contributionsfor such purposes.

At times, LifePoint may ask employees to makepersonal contact with government officials or towrite letters to present our position on specificissues. In addition, it is a part of the role of someLifePoint management to interface on a regularbasis with government officials. If you are makingthese communications on behalf of theorganization, be certain that you are familiar withany regulatory constraints and observe them.Guidance is always available from the CorporateGovernment Relations and Legal departments asnecessary.

Political Activities and Contributions

Page 22: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir
Page 23: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

21

Personal Obligation to Report

We are committed to ethical and legal conductthat is compliant with all relevant laws andregulations and to correcting wrongdoingwherever it may occur in the organization. Eachemployee has an individual responsibility forreporting any activity by any employee, physician,subcontractor or vendor that appears to violateapplicable laws, rules, regulations or this Code.

Internal Investigation of Reports

We are committed to investigate all reportedconcerns promptly and confidentially to the extentpossible. The corporate ethics and complianceofficer will coordinate any findings from theinvestigations and immediately recommendcorrective action or changes that need to be made.We expect all employees and physicians tocooperate with investigation efforts.

Corrective Action

Where an internal investigation substantiates areported violation, it is the policy of LifePointHospitals to initiate corrective action, including, asappropriate, making prompt restitution of anyoverpayment amounts, notifying the appropriategovernmental agency, instituting whateverdisciplinary action is necessary and implementingsystemic changes to prevent a similar violation fromrecurring in the future at any LifePoint facility.

The Corporate Ethics and Compliance Program cont.

Page 24: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

22

The Corporate Ethics and Compliance Program cont.

Discipline

All violators of the Code of Conduct will be subjectto disciplinary action. The precise discipline utilizedwill depend on the nature, severity and frequencyof the violation and may result in any of thefollowing disciplinary actions:

� verbal warning

� written warning

� written reprimand

� suspension

� termination

and

� restitution (if necessary).

Internal Audit and OtherMonitoring

LifePoint Hospitals is committed to the aggressivemonitoring of compliance with its policies. Much ofthis monitoring effort is provided by Internal Auditand the Compliance department, which routinelyconduct audits of issues that have regulatory orcompliance implications. The organization alsoroutinely seeks other means of ensuring anddemonstrating compliance with laws, regulationsand LifePoint policies.

Acknowledgment Process

LifePoint Hospitals requires all employees to sign anacknowledgment form confirming that they havereceived the Code of Conduct and understand thatit represents mandatory policies of LifePointHospitals. New employees will be required to signthis acknowledgment as a condition of employment.

Adherence to and support of LifePoint Hospitals’Code of Conduct and participation in relatedactivities and training will be considered in decisionsregarding hiring, promotion and compensation forall candidates, employees and physicians.

Notice to All EmployeesRegarding Fraud

The Deficit Reduction Act of 2005, signed intolaw by President Bush on February 8, 2006,contains specific requirements regarding entitiesthat receive more than $5 million annually fromMedicaid. The law, effective January 1, 2007,requires that entities covered by the law havespecific policies dealing with matters of fraudand abuse. In addition, employees are to beinformed about a federal law known as the FalseClaims Act, a civil anti-fraud statute providingthat any person who knowingly submits orcauses the submission of false claims forgovernment funds or property is liable fordamages and penalties. Entities that knowinglyviolate this law can be liable for triple damagesand a penalty from $5,500 to $11,000 per claim.

The False Claims Act contains provisions forindividuals who are known as “relators,” orwhistle blowers. The law provides certainprotection for employees who are retaliatedagainst by an employer because the employeefiled a whistle blower lawsuit. Individuals whohave questions regarding the specifics shouldrefer to LifePoint’s policies for additionalinformation.

Page 25: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

I acknowledge that I have received LifePoint Hospitals’ Code of Conduct. I understand that it representsmandatory policies of the organization, and I agree to abide by it.

Signature _____________________________________________________________________________________________

Position _______________________________________________________________________________________________

Printed Name__________________________________________________________________________________________

Date __________________________________________________________________________________________________

Facility ________________________________________________________________________________________________

Acknowledgment

23

Page 26: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir
Page 27: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir

Notes

Page 28: CommonGround Code of Conduct - Conemaugh Health System · WhileallLifePointHospitalsemployeesare obligatedtofollowourCode,weexpectour leaderstosettheexample—tobeineveryrespect amodel.Leadersmustensurethatthoseontheir