Code of Business Conduct and Corporate Standards
All employees, officers and
directors of the company and its subsidiaries:
- Shall perform their duties in good faith and to the
best of their ability.
- Shall refrain from any illegal conduct.
- Shall not obtain any improper personal benefit by
virtue of his or her employment with UHS, shall not misuse company assets
or use corporate information or opportunities for personal gain, and shall
not engage in any relationship or financial interest which is a conflict
of interest with, or which interferes or has the potential to interfere
with, the interests of UHS or any of its subsidiaries or facilities.
- Shall not accept (1) any gift of more than nominal
value or (2) any hospitality or entertainment which because of its source
or value might influence the employee's, officer's or director's
independent judgment in transactions involving UHS or any of its
subsidiaries or facilities.
- Shall disclose to the VHS compliance officer any
financial interest or ownership interest or any other relationship that he
or she (or a member of his or her immediate family) has with customers,
vendors, or competitors of VHS or any of its subsidiaries or facilities.
- Shall not engage in any business practice intended to
unlawfully obtain favorable treatment or business from any government entity,
physician, potion, vendor, or any other party in a position to provide
such treatment or business.
- Shall not solicit or receive from any person or entity,
nor offer or give to any person or entity, anything of value if that
person or entity is in a position to refer business to UHS or any of its
facilities or if UHS or any of its facilities is in a position to refer
business to that person or entity.
- Shall not use confidential or proprietary information
of UHS, its facilities, patients, vendors, or customers for his or her own
personal benefit or for the benefit of any other person or entity, while
employed at UHS or any of its subsidiaries, or at any time thereafter.
- Shall not buy or sell UHS or any other stock based upon
"insider" information about or involving UHS, not pass on any
such information to others, including, but not limited to, friends and
- Shall not participate in any conduct, agreement or
understanding (including agreements based upon a course of conduct) with a
competitor of UHS or anyone else to illegally fix prices, agree to labor
costs, allocate markets, engage in group boycotts, inappropriately
manipulate or conceal information, misrepresent material facts, abuse
privileged information or engage in any other unfair practice.
- Shall not provide any gifts to any government or public
- Shall notify either the UHS general counsel, the
facility's compliance officer, or the chief executive officer of the UHS
facility in which he or she works, who will in turn notify the UHS general
counsel, immediately upon the receipt (at work or at home) of an inquiry,
subpoena or other agency or government request for information regarding
UHS or any of its subsidiaries or facilities (other than for medical
records or other routine licensing matters).
- Shall not destroy or alter any information or documents
in anticipation of, or in response to, a request for documents by any
applicable governmental agency or from a court of competent jurisdiction.
- Shall not disclose confidential medical information
pertaining to UHS facilities' patients without the express written consent
of the patient and in accordance with applicable law and UHS facilities'
applicable policies and procedures.
- Shall not participate in any false billing of patients,
government entities, or any other party.
- Shall promptly report all suspected violations of this
Code of Business Conduct and Corporate Standards by other employees,
officers or directors to (1) the UHS compliance hotline (1-800-852-3449),
or (2) the compliance post office box (Universal Health Services, Inc.,
P.O. Box 61823, King of Prussia, PA, 19406-8823), or (3) his or her
immediate supervisor or the facility's compliance officer.