TheKey_Principles_Code_of_Conduct.txt

TheKey Principles - Code of Conduct and Ethics. Message from Tad Smith, Chief Executive Officer: Dear Colleagues, As a trusted team member, you are a part of an organization that provides exceptional home care and home health services to older adults, allowing them to age-in place comfortably and independently. We developed TheKey Code of Conduct and Ethics, or The Principles to ensure that we consistently deliver quality care and operate with integrity. These Principles serve as a guide for all of us, including employees, independent contractors, officers, and directors. They help us perform with the highest ethical and legal standards. Our Principles are also a crucial component of our overall Compliance Program. Violating any of the laws or regulations prohibited by TheKey or its Principles is expressly forbidden. Employees who violate these Principles are acting outside the scope of their employment and could face disciplinary action, including termination. About TheKey: For nearly 20 years, TheKey (formerly Home Care Assistance) has helped clients achieve successful long-term aging at home with comprehensive, concierge-based care. Founded in Silicon Valley, TheKey has grown from a single location to service coverage throughout North America. Our Mission: Be the most trusted source of long-term care for aging at home. Our Vision: Change how the world lives and ages at home. Our Values: Passion - Let caring for others inspire us every day. Compassion - Show kindness and respect to all clients, Caregivers, and co-workers. Innovation - Find innovative solutions to improve our service and our company. Above and Beyond - Go the extra distance, and always do the right thing. The Principles contain 4 elements: Principle 1 Excellence, Principle 2 Client Focused, Principle 3 Integrity, Principle 4 Partnership. PRINCIPLE 1 EXCELLENCE: We pursue the best and constantly seek improvement. This means being accountable, following regulations, and maintaining accurate records. 1. Accountability and Discipline: We work daily to achieve TheKey mission, vision, and values. Leadership must cultivate an honest, open culture where colleagues can speak up without fear. Leadership responsibilities include modeling values, fostering integrity and compliance, creating safe environment for questions, providing guidance, evaluating performance, never encouraging or tolerating violations. Colleague Responsibilities: Follow the law and relevant company policies, proactively live our values, foster open-door culture, use company resources to make informed decisions, discuss suspected misconduct with a manager. 2. Accuracy of Information and Reporting: We make sure information is fair, accurate, complete, and timely. We will not tolerate false or misleading records. Follow the company system of internal controls. Cooperate fully with auditors. Report errors or inaccuracies immediately. 3. Billing and Documentation: We bill in compliance with applicable laws, regulations, policies, and procedures. Provide necessary services with accurate documentation. Submit truthful information. Disclose billing errors and refund wrongful payments. Report and refund overpayments to Federal healthcare programs within 60 days. 4. Licenses and Certifications: We only employ qualified, licensed professionals. We do not hire or contract with OIG-sanctioned individuals or entities. Keep professional qualifications up-to-date. Report any license expirations, lapses, suspensions, or sanctions immediately.
5. Policies and Procedures: Employees must follow all relevant laws and regulations and be familiar with work responsibilities. Follow TheKey policies, request clarification if needed, report any behavior that contradicts The Principles. 6. Record-Keeping, Record Retention, and Record Destruction: We maintain accurate and secure records in compliance with legal requirements. Records are kept for the appropriate length of time and are not altered or destroyed to evade requests by government agencies or courts. Follow the company record retention policies and protect confidentiality when disposing of records. 7. Training and Education: Complete required education and training on time as a condition of continued employment. Take advantage of additional learning opportunities. 8. Recruiting and Compensation: We recruit and compensate employees according to strict legal requirements including Anti-Kickback regulations. Make sure recruitment and compensation arrangements meet fair market value standards. Avoid arrangements that include any incentives to induce referrals. PRINCIPLE 2 CLIENT FOCUSED: We treat everyone with respect and dignity, build trust, create meaningful relationships, and support each client capabilities, interests, and passions. 1. Quality of Care: Our first responsibility is to our clients and their families. Provide the best level of care possible. Treat every client with respect and compassion at all times. Respond to all client questions, concerns, and needs in a timely manner. Maintain the confidentiality of client records. 2. Information and Property Security: We protect information through security measures that maintain confidentiality, integrity and appropriate availability of data. Always communicate protected information in a secure way. Never communicate information to unauthorized persons. Honor the privacy of clients. Keep computing devices secure and registered, approved and encrypted to company standards. Report any data security concerns immediately to the IT Support Center. 3. Client Rights: Our clients have the right to receive care that is safe, appropriate and respectful without regard to race, marital status, gender, sexual orientation, gender identity, national origin, age, disability, religion, or veteran status. Listen to and act on the client wishes about their care. Respect advance directives. Respect each client spiritual and cultural values. Never delay emergency care for any non-medical reason. 4. Client Privacy: We honor the trust that clients place in us by protecting their information. Access, use, and release protected information only as allowed by privacy policies. Only access client information when necessary for work-related purposes. Do not discuss clients with anyone who is not authorized. Do not gossip about clients. Report any privacy concerns immediately. 5. Referrals of Care and Services: We will not provide or accept kickbacks, bribes, rebates, or anything of value to influence referrals. Follow all laws about referring clients to other providers. Never solicit, accept or offer anything of value in exchange for client referrals.
PRINCIPLE 3 INTEGRITY: We are open and honest, and we honor our commitments in good faith. We keep others best interests in mind, with the goal of creating joy and purpose for those we serve every day. 1. Business Information and Intellectual Property: Treat all confidential business information with care. Obtain approval before sharing any business information outside the company. Do not disclose or use confidential information for personal benefit. Keep all trade secrets and non-public information confidential. Do not discuss potential business relationships, purchases, mergers, or acquisitions outside the company. Maintain confidentiality even after your association with the company ends. 2. Conflicts of Interest: We offer care that is objective and based on best available evidence. Decisions about care and services are free from the influence of personal gain. Avoid personal relationships that could interfere with your ability to work objectively. Disclose all outside interests involving competitors. Never use information from your work for personal investment or gain. Do not use your position for your own or anyone else gain. Report actual or perceived conflicts of interest to your leader. 3. Antitrust and Fair Competition: We comply with antitrust laws and laws that encourage fair trade and competition. Only use legal methods to obtain information about competitors. Ensure sales materials accurately describe our products and services. 4. Fraud, Waste, and Abuse: We work to prevent, detect and correct fraud, waste and abuse. We do not tolerate cheating, stealing, theft, deception or acts of fraud. We discipline anyone engaged in inappropriate behavior, up to and including termination. We cooperate fully with regulators and law enforcement. Be aware of potential fraud, waste or abuse and report it. Participate in regular training. 5. Gifts: Do not accept cash or cash equivalents from clients or others. Small tokens like cards, flowers or candy may be accepted. Never offer or accept gifts to or from government officials. 6. Government Officials and Government Inquiries: Forward any non-routine requests for information to the Legal Department. Respond within requested time frame with truthful and accurate information. Never impede or obstruct any government audit, review or investigation. 7. Compliance Program: Our company has a Compliance Program to prevent, detect and correct violations. Follow all compliance policies and procedures. Complete compliance-related trainings on time. Voice good faith concerns through multiple reporting channels including the Compliance Hotline. 8. Non-Retaliation: We will not impose disciplinary action or retaliation when there is a good faith report of a perceived issue. The company will take disciplinary action against anyone that penalizes, ostracizes or harasses someone who has reported concerns honestly. Report any activity you believe may violate laws, regulations, policies or The Principles. Do not retaliate against anyone who raises a concern in good faith. 9. Outside Employment and Consulting Arrangements: Discuss with your leader before agreeing to outside employment. Disclose all details for review. Never use company information as part of outside work. 10. Personal and Public Communications: When communicating publicly about the company, avoid statements that could be viewed as unlawful, profane, discriminatory, threatening or hateful. Be clear whether speaking as an individual or on behalf of the company. Follow company policies on privacy and social media. Contact Communications team if contacted by media. 11. Truthfulness and Cooperation: Be truthful in daily actions, work product, care documentation, time reporting, and expense reports. Be truthful in regulatory and legal filings. Cooperate with regulators, law enforcement, and auditors. Contact Legal team immediately if you receive a summons, subpoena, or other communications from courts or government agencies.
PRINCIPLE 4 PARTNERSHIP: We promote diversity, open dialogue, and growth for our team and communities. Our culture values effective communication, inclusiveness, and respect globally. 1. Diversity and Inclusion: We welcome a diversity of cultures in building a workplace that embraces, values, and celebrates our differences. We believe the diversity of our workers is a great asset. We do this by listening to unique points of view, championing the strengths of our differences, removing barriers to inclusion, leading by example to inspire empathy and compassion, being fully committed to equality, promoting equity in every aspect of our business. Be respectful of your colleagues cultures, values and differences. 2. Harassment and Discrimination: TheKey maintains a discrimination and harassment-free workplace. We condemn all forms of discrimination and harassment, including those based on race, sex, religion, age, disability, sexual orientation, gender identity, and more. Do not discriminate. Report immediately if you feel you have been the subject of, have witnessed, or been told of any incidents of harassment or discrimination. Treat everyone with dignity and respect. 3. Human Rights and Anti-Slavery: We are unwavering in our dedication to universal human rights, as outlined in the United Nations Declaration of Human Rights and modern slavery laws. We lead by example and conduct due diligence to prevent violations. 4. Safe Work Environment: We are committed to maintaining a work environment that is safe and secure. Make workplace safety one of your responsibilities. Follow all workplace health and safety laws and policies. Report unsafe conditions right away. 5. Alcohol, Tobacco, Weapons, and Controlled Substances in The Workplace: Do not use alcohol or illegal drugs while working or on call. Do not bring illegal drugs, weapons, or other contraband to your workplace. Do not perform job duties under the influence. Do not smoke or use tobacco in your workplace. 6. Environmental Stewardship and Sustainability: We care for the places where we live and work. Use and dispose of resources mindfully. Reduce consumption of materials and energy. Recycle or dispose of materials responsibly. Follow all laws addressing hazardous substances and waste. Ethical and Legal Decision Making Framework: Ask these questions: Is it legal? Would it benefit the organization? Would it enhance our reputation? Would I be comfortable if published in news? Is it consistent with TheKey Principles of Excellence, Client Focused, Integrity, Partnership? If in doubt, ask for help from your leader, Legal, or HR. Making Decisions TheKey Way: CAN We Do It? Is it permitted by law? If not sure, consult with others. If no, contact Legal. SHOULD We Do It? Is it ethical and consistent with our values? If not sure, consult. If no, contact HR. HOW Do We Do It? Will it enhance our culture and reputation? If not sure, consult. If no, discuss with your manager. If all yes, proceed with confidence knowing your actions are legal, ethical, and respectful. How to Report Concerns: Report suspected violations to Chief Compliance Officer at compliance@thekey.com or call the Compliance Hotline anonymously. Retaliation for reporting will not be tolerated. For crisis escalation or ethical concerns, contact 911@thekey.com. Leaders must accept responsibility for listening carefully and respectfully, thank the reporter for upholding values, take every concern seriously, communicate commitment to addressing the issue, protect confidentiality, and promote the right of all to be free from harassment, bullying, and discrimination.