Unity’s Corporate Compliance Program
Unity Health Care (“Unity”) is committed to conducting business in compliance with all applicable laws, rules and regulations. Unity has established a Corporate Compliance Plan and related Corporate Compliance policies and procedures (including Unity’s Standards of Conduct) to assist in developing a proactive and effective Corporate Compliance Program.
Unity’s Corporate Compliance Plan provides an overview of the components of the Corporate Compliance Program and an overview of applicable compliance related laws, rules and regulations. It is Unity’s objective to comply with all federal and District of Columbia laws, rules and regulations, as well as to use general good business practices to protect its reputation and to avoid or prevent non-compliance.
Unity has established a series of policies and procedures designed to assist in:
- Detecting instances of non-compliance;
- Promoting open lines of communication so individuals feel comfortable reporting compliance issues and questions; and
- Responding to instances of non-compliance that are discovered.
Unity refers to this series of policies and procedures (which includes the Corporate Compliance Plan) at its Corporate Compliance Program.
Reporting Compliance Issues
Any individual affiliated with Unity who is aware of or suspects a violation of an applicable law, rule or regulation, Unity’s Standards of Conduct or other policies and procedures has an affirmative duty to report this information. All reports of alleged, known or suspected non-compliance should be reported through the regular chain of command. Any individual who, for any reason, is uncomfortable with reporting through the normal chain of command should report the information directly to the Office of Corporate Compliance.
Unity has a formalized system of communication for individuals affiliated with Unity to report potential non-compliance to the Office of Corporate Compliance. An individual may communicate information to the Compliance Officer directly by calling the Compliance Hotline at (202) 299-1756; by sending an e-mail to firstname.lastname@example.org; or by sending a letter to:
Corporate Compliance Officer
Unity Health Care, Inc.
1220 12th Street, SE, Suite 120
Washington, DC 20003
Unity takes all necessary steps to maintain the confidentiality of the identity of the individual who has reported information. However, at some point the identity of such individual may need to be revealed in order to appropriately address the reported matter. Individuals may make anonymous reports through the hotline or by letter, though it is preferred that individuals identify themselves as part of the report to allow for a comprehensive review of the report.
Duty to Report
Failure to report instances of suspected unethical or non-compliant conduct is considered a violation of the Corporate Compliance Program. Disciplinary actions that may be taken include, but are not limited to oral warning, written reprimand, suspension and/or termination. Managers and supervisors may be subject to disciplinary action for failing to detect noncompliance with applicable law or policies and procedures where reasonable diligence on the part of the manager or supervisor would have led to the discovery of a problem or violation.
No retaliatory action will be taken against any individual who, in good faith, reports suspected or known instances of non-compliance. Anyone who is involved in an act of retaliation, intimidation or harassment of an individual who reports a compliance concern in good faith will be subject to disciplinary action.