Compliance Program

Major Components of Compliance Program
  1. Code of Conduct
  2. Code Of ethics
  3. Conflict of Interest
Objectives of Program
Ensure compliance with all applicable laws, regulations and PHI policies. As well as
PHI Agency Director is the compliance officer and as such is responsible overall for the program. Any potential or known violations of the compliance program should be reported to the compliance officer. Anonymous reports will be investigated thoroughly as well. PHI requires employees to report any known or potential violations of law, regulations or PHI policies to the Compliance officer. Management will respond appropriately and promptly when violations are identified. Disciplinary action will occur as appropriate. PHI will determine if violations are related to gaps in policies, company practices or internal controls. PHI will take appropriate actions to prevent future violations.

O-2-126 Code of Conduct

Policy
The agency is committed to providing a safe and welcoming environment for all employees and clients. To promote safety and comfort for all, the agency asks individuals to act appropriately at all times when they are in the agency offices or other service locations. Policy is applicable to all agency staff and representatives.

Guidelines
Employees are expected to behave in a mature and responsible way and to respect the rights and dignity of others. The agency code of conduct does not permit language or any action that can hurt or frighten another person or that could affect operations. Specifically, this includes, but is not limited to:
Procedures
Employees are encouraged to be responsible for their personal comfort and safety and ask any person whose behavior threatens their comfort to stop such behavior. If an employee feels uncomfortable in confronting the person directly, they should report the behavior to a supervisor. Supervisors should contact the appropriate departmental director if they feel any employee action warrants disciplinary action.

O-2-127 Conflict of Interest

Policy
All agency employees will not engage in activities contrary to the agency’s interest or in activities inconsistent with the responsibilities entrusted to them. In general, there is conflict whenever an employee achieves personal gain or incurs obligation to others at the expense of the agency. Such personal gain need not be direct and might include gain by employee’s family members or other relatives. Guidelines
The following list includes areas where a conflict of interest is likely to arise, but it is not meant to limit the areas where employees should exercise discretion:

Procedures
The agency director is the corporate officer who determines whether any specific transaction, relationship or other situation represents a conflict of interest. If determined to be a conflict of interest employment can be terminated.
Click the Compliance Program link on the right to take the test.