COMPLIANCE STANDARDS OF CONDUCT

The following are the basis for the integrity of Alevio Business Practices.

Ethical practices.

Clients have a right to expect that Alevio will conduct business ethically and competently.  Each employee should adhere to the language of this Compliance Program when performing all duties directed from Alevio.

Employee conduct.

  • Each employee should perform all Alevio duties in good faith, and in a manner that is in the best interest of Alevio.
  • Each employee should be honest in the employee’s business relationship with other employees, officers, legal counsel, accountants and consultants. The failure to deliver information to appropriate personnel is unacceptable and could lead to termination.

 

Improper payments.

No employee shall engage in or assist in, either directly or indirectly, any corrupt or inappropriate business practice, including kickbacks, payoffs, bribery, intended to induce, influence or reward favorable decisions of any government personnel or representative, any patient, physician, or vendor. No employee shall make or offer to make any payment or provide any other thing of value to another person with the understanding or intention that such payment is to be used for an unlawful or improper use.

Business entertainment and gifts.

Alevio may provide entertainment and gifts that do not violate federal, state, and local laws. These gifts may be given only with prior approval from the Compliance Officer.  Cash and non-cash gifts to referral sources for the purposes of inducing referrals are absolutely prohibited.

Fair Dealing.

Each employee, director, officer and independent sales representative will deal fairly with Alevio customers, suppliers, competitors, affiliates, independent auditors, and other employees and will not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing or practice.

Protecting Patient Information.

Alevio will protect the confidentiality of all patient information in full compliance with all federal, state, and local laws, and safeguard such information from misuse, alteration, theft, fraud, unauthorized disclosure and unauthorized use.

 

Alevio may from time to time adopt additional and specific Standards of Conduct under this program in which it will circulate to the employees at the appropriate time it takes effect. In addition, Alevio has established and maintained policies and procedures not set forth in this Compliance Program.  Additional practices, procedures and policies of Alevio are an integral part of this Compliance Program.  All employees are expected to comply with all such practices, procedures and policies.  Employees are expected to act in accordance with the law and seek guidance from the Compliance Officer or an officer of Alevio if in doubt of the legality of any conduct.