code of conduct - athenahealth · code conduct 2019 page 3 at athena, we aspire to a culture that...

CODEOF

CONDUCTtransforming healthcare

with integrity

CODE OF CONDUCTEffective February 15, 2019

page 2

OURETHICS

ARERADICALLY

SIMPLE.WE WANT TO DO WHAT’S RIGHT.

We follow the law

We arerefreshinglycandid

We act with integrity

We are safeand smartwith dataand assets

We treat each otherwith dignity and respectWe push

boundariesresponsibly

that means

We are honestand responsible

with athena’smoney and

resources


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At athena, we aspire to a culture that is as versatile, open, accepting, and trustworthy as the platform we are building to power the future of healthcare; a culture rooted in radical simplicity that hacks away at the inessentials so we can focus on work that is most powerfully relevant to our mission. Our culture is refreshingly candid in a way that transcends typical corporate clichés. It is truly respectful of and to all who join us on our journey. We push boundaries every day, without compromising our integrity or the trust that our clients place in us. We seek and reward employees and partners who share these same values.

We are all expected to uphold, promote, and enforce our company values and commitment to a culture of integrity. Our Code sets forth the parameters by which we sustain those values, abide by our commitment, and pursue our mission. It provides guidance that applies to all athenistas, regardless of tenure or cohort. It also imposes special responsibilities on Leaders (employees at the Director cohort and above), who are expected to act as mentors, role models, and points of inspiration.

Our Code is not exhaustive of all expected behaviors. Rather, it builds on the overarching expectation that we act honestly, ethically, lawfully, and in the best interests of athena at all times. We must not use loopholes, shortcuts, or technicalities to avoid following the letter and spirit of the guidance in our Code. If you are unsure of the right thing to do, or believe you are being asked to do something that may be improper, ask for guidance using the resources provided in our Code before taking action.

We are transforming healthcare with integrity. Integrity is not optional; it is the foundation of who we are and how we will succeed. Every athenista is expected to know, understand, and follow the guidance in our Code. If you have questions, speak up, and you will be guided in the right direction.

Thank you for acting with integrity in all that you do for athena.


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DO WHAT’S RIGHT.WE FOLLOW THE LAWathenistas are not expected to be experts in the law, but we are expected to be familiar with the laws relevant to our roles, to use good judgment, to spot potential issues and,when we do, use the resources available to ensure we get it right.

WE ACT WITH INTEGRITYTransparency is a hallmark of integrity. We must all be transparent about our actionsand the options we are considering so that – as a collective whole – we can decide ona course that is the right course in every situation.

WE ARE SAFE AND SMART WITH DATA AND ASSETSOur clients and their patients trust us with their valuable data. One way to continueto earn that trust is to be safe and smart when we build, utilize, and operationalize the products and services that impact data. Securing data appropriately and using it theright way must be at the core of everything we do.

WE PUSH BOUNDARIES RESPONSIBLYWe must challenge conventions in order to open up the network, multiply ourintelligence, and free people to do what matters – but we must do so in a smart and responsible way. Our work affects the health and safety of over 100 million people.It is our responsibility to ensure their wellbeing remains at the forefront of our individual and collective efforts.

WE TREAT EACH OTHER WITH DIGNITY AND RESPECTathenistas are most powerfully relevant when we are treated with dignity and respect.We deserve to be treated honestly and fairly – and we must treat others the same way, regardless of who they are or where they fall on an org chart. athena has policies thatdrill down on what this means and the behaviors expected from each of us; we must allbe familiar with and follow them.

WE ARE HONEST AND RESPONSIBLEWITH ATHENA’S MONEY AND RESOURCESathenistas are empowered and trusted to spend Company money. That includes hiring top talent, working with best-of-breed vendors and technologies, meeting with prospects to build a business relationship, and more. To maintain that trust, we are all expectedto be truthful and responsible with how we spend Company money.

WE ARE REFRESHINGLY CANDIDPart of being refreshingly candid means feeling empowered to speak up. This includes raising concerns when you feel uncomfortable or believe someone may have acted improperly. It also means reporting situations when you believe our clients, vendors,or business partners may be acting inappropriately.


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WE FOLLOW THE LAWThere are a lot of laws that apply to athena and a big part of following them is understanding them. Some laws are easy, like: don’t steal. Some are complicated, like: proper cost allocation on government reporting. We are all expected to be familiar with and follow the laws and Company policies that apply to our roles and the work we do. To help meet that expectation, proactively utilize our lawyers, compliance professionals, employee relations team, and other resources when you need help or see something that doesn’t sit right – issue spotting and raising concerns when something feels wrong is part of every athenista’s job description.

Certain laws are core to our business, including: HIPAA AND PRIVACY LAWS: require sensitive information remain confidential and accessible only to those who are authorized to see it. These laws apply to various kinds of information, including protected health information, personally identifiable information, credit card and financial information, and other sensitive information.FALSE CLAIMS LAWS: prohibit knowingly or intentionally including false information on a claim for payment submitted to a government payer, or being deliberately ignorant (think head in the sand) to the fact that the information is false.ANTI-KICKBACK LAWS: prohibit giving anything of value to induce referrals of patients or healthcare products and services that are paid by federal healthcare programs. Our lead generation and other programs are carefully considered and designed to comply with these laws to the extent these laws apply to us. We use gifts and hospitality for their proper purpose, to build a business relationship and to reflect esteem or gratitude. Any hospitality, gift, or charitable donation must be given without expectation of anything in return and should never be offered to influence a business decision.

Depending on our roles, there are other laws that may relate to our work at athena: BRIBERY: we can, do, and must win business the right way – on the strength of our products, services, and people. athena complies with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act. ANTITRUST AND FAIR COMPETITION: we believe in competing on a fair and level playing field and are confident clients will choose us because of our strengths. athena follows all applicable antitrust and fair competition laws, which are designed to prohibit practices placing an unreasonable restriction on trade, commerce, or competition. These laws are often particularly complex and may, in some instances, be counterintuitive. Rely heavily on the resources athenaprovides internally – nobody needs to go it alone. CUSTOMS AND TRADE: regardless of where our business takes us throughout the world, athena complies with all applicable customs and trade laws, including rules and regulations concerning trade controls, exports, re-exports, and imports.

code ofconduct

Follow the law.BE FAMILIAR WITH AND FOLLOW THE LAWS applicable to the work you do. Ignorance of the law is not an excuse.

UNDERSTAND COMPANY POLICIES that apply to you and follow them, unless you have received an exception from the policy owner.

IMMEDIATELY REPORT any situation where you believe someone has done something improper or if anyone asks you to do something that you believe is improper.

ENGAGE LEGAL AND COMPLIANCE EARLY in the product development process and before initiating any new marketing, sales, or incentive campaigns.

SET THE TONEemphasize the importance of doing the right thing.

LEAD BY EXAMPLEp y j pproactively reach out to our subject matter experts.

KEY TAKEAWAYY TTAAKKKEEAAAWWKEY WAATAAKKEEAEYY T AWWWA

LEADERSare additionally

expected to…

FOR MORE INFORMATION:

C-300 HIPAA PolicyG-109 Fraud and Abuse PolicyC-205 Anti-Bribery PolicyG-107 Business Payments and Gifts Policy


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WE ACT WITH INTEGRITYIntegrity is essential to our success, and our commitment to integrity starts with our employees. All athenistas are asked to work hard, do work that is powerfully relevant, and push ourselves and the boundaries of healthcare in new and innovative ways for the betterment of each other, our Company, and, ultimately, the millions impacted by what we do. We must all do this work purposefully, and never in a way that compromises our integrity.

Our commitment to integrity extends to our clients, business partners, and every person impacted by the work that we do. If people think our business judgment or objectivity is affected by personal motivations, we lose trust. Avoid conflicts of interest, including situations where others might believe our business decisions are being made for the wrong reasons, even if they are not. Examples include self-dealing, steering athena business to a company you or a family member holds a financial interest in, holding another job with a client, competitor, or other company that detracts from your work at athena, interfering with or diverting athena business opportunities, or accepting gifts or personal benefits that might seem to influence business decisions. If a potential conflict does arise, notify your manager and promptly stop whatever action is creating the conflict until you receive guidance.

code ofconduct

Act with integrity.BE HONEST, TRANSPARENT, AND ETHICAL in all business dealings, internally and externally.

USE GOOD JUDGMENT to promote athena’s legitimate business interests over your own personal or financial interests.

ACT AND LEAD WITH INTEGRITYboth through their words and actions.

DO WHAT’S RIGHTnot necessarily what’s easy.

DO NOT SCAPEGOATor think a different set of rules applies because of a higher cohort.

HOLD THEMSELVES AND OTHERS ACCOUNTABLEwhen actions do not conform with our values or commitments.

KEY TAKEAWAYTTAAKKEEAAWWWEEY AAYAAKKEEAAEY T WWAA


expected to…


G-114 Conflict of Interest PolicyC-500 Travel and Expense PolicyG-107 Business Payments and Gifts PolicyC-205 Anti-Bribery PolicyG-109 Fraud and Abuse Policy


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WE ARE SMART AND SAFE WITH DATA AND ASSETSA test. A diagnosis. A medical condition. Each can represent a life-defining moment. Whether life-defining or mundane, building safe, smart, and secure products that work how they are supposed to work is essential. We must build functionality that uses only the minimum amount of health or other information necessary. We must develop microservices using our security best practices, and use data in a manner that is transparent, consistent with our contracts and regulatory obligations, and is otherwise deserving of the trust our clients place in us. As a business associate to our clients, we are trusted to comply with HIPAA and related federal and state privacy laws. This includes following the Company’s record retention policies and being thoughtful about where, how, and when we store or dispose of business records, communications, and documents.

Proper handling of data and assets extends beyond PHI. We have an open and transparent culture, which includes sharing athena’s confidential information internally where appropriate. We are all trusted to treat this information the right way, handle it carefully, use it only for legitimate business purposes, and keep it confidential. That means we must not disclose athena’s confidential information outside the Company unless appropriate confidentiality or non-disclosure agreements are in place and there is a legitimate business reason to do so. This includes communications in personal or private settings, as well as public communications such as announcements, speeches, interviews, blogs, tweets, or any other forum. If you are unsure whether information is confidential, ask your manager or the athenista responsible for that information. If still unsure, escalate to Legal.

Depending on your role, you may also have access to confidential information belonging to an athena client, vendor, or business partner. Treat this information the same way you would treat

confidential information belonging to athena. There is never a good reason to post confidential information onsocial media or other public-facing platforms, no matter who it belongs to.

code ofconduct

Be smart and safe with data and assets.CONSIDER how your actions may impact the privacy or security of sensitive information.

FOLLOW THE COMPANY’S SECURITY POLICIES and never circumvent the physical, technical, or administrative safeguards in place.

TREAT ALL CONFIDENTIAL INFORMATION APPROPRIATELY, no matter who it belongs to.

IMMEDIATELY REPORT MISTAKES that you believe create a security or patient safety risk.

PRIORITIZE SECURITY AND PATIENT SAFETYin all that they do and all that they ask their teams to do,

even if it slows them down or costs more.

MAINTAIN CONFIDENTIALITYabhor swirl, rumor, and other wastes of time.

KEY TAKEAWAY


expected to…


G-105 Confidential Information Policy

G-108 Insider Information Policy

G-104 Records Management and Communications Tools

G-112 Social Media Policy

C-300 HIPAA Policy

C-600 General Athena Information Systems Use Policy

C-800 Physical Security Policy


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WE PUSH BOUNDARIES RESPONSIBLYDo what matters most. Predict what matters next. Connect people to what they need, when they need it. Transforming healthcare requires thinking outside the box, not only with respect to what we develop internally, but also in who we choose to partner with. At athena, we fully embrace this challenge and are committed to getting there in a way that does not compromise patient safety or the integrity of our products and services.

Patient safety must be a priority in all that we do. New products and services must be thoroughly vetted and reviewed to ensure they comply with applicable patient safety standards, laws, and security requirements. Test products and services methodically and repeatedly before pushing them into production. Never let the pressure of deadlines or schedules compromise our commitment to building the right thing in the right way. If there is ever a situation where something may present a patient safety concern, or is not in line with legal or regulatory requirements, report it immediately.

Partnerships, vendor relationships, and third-party affiliations are necessary to achieving our mission. We welcome and seek out new ideas, integrations, and opportunities, but we must not let the shine of the new distract or detract from our values and commitments. We are all responsible for ensuring business partners are appropriately assessed prior to giving them access to our systems, and for ensuring that third-parties we work with share similar values to our own.

code ofconduct

Push boundaries responsibly.BE MINDFUL of how your work could impact patient safety, information security, or legal compliance; reach out to our subject matter experts for guidance.

NEVER CUT CORNERS to meet a deadline.

BE THOUGHTFUL about who you choose to partner with athena.

NEVER LET INTERNAL OR EXTERNAL PRESSURESaffect the quality of our products and services.

INSTRUCT THEIR TEAMSto avoid business partners that could jeopardize our reputation.

KEY TAKEAWAY


expected to…


C-620 Vendor Management Policy


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WE TREAT EACH OTHER WITH DIGNITY AND RESPECTEach of us is responsible for fostering a culture that helps unleash our collective potential. This means treating each other with dignity and respect and embracing the virtues of diversity and inclusion in our words and our actions. We are all encouraged to say what we mean and mean what we say, and to give and accept feedback that is refreshingly candid, so long as we do so in a respectful and productive way. We must all use the technology and internal communication tools athena offers for their intended purpose: to foster meaningful and productive conversations that are about the work we have done or need to do; not to distract us from what matters. athena promotes a respectful working environment free from discrimination, harassment, and other threats. We have no tolerance for discrimination or harassment of any kind. This means:

All decisions with regard to hiring, termination, review of job applications, performance evaluations, promotions, demotions, transfers, work assignments, accommodations, compensation, benefits, and all other employment matters are made without regard to a person’s race, color, gender, gender identity, sexual orientation, national origin, religion, disability, age, pregnancy, genetic information, marital or family status, veteran status, or political affiliation.

Business decisions concerning clients, vendors, suppliers, business partners, or other entities are also made solely on the merits and are not influenced by any of the factors listed above. Our commitment to ensuring all athenistas are treated appropriately extends beyond our internal interactions. We all have the right to be treated respectfully while engaging with clients, prospects, vendors, or other business partners – whether on athena premises or at offsite locations. athena has programs and policies in place to ensure this right is realized.athenistas are also encouraged to participate in legal or political organizations of their own choosing and to engage in the political process or with their political representatives. Nobody will be penalized, harassed, or intimidated for their decision to join, refrain from joining, or engage in those activities. When doing so, however, do not use athena, athena’s name, or athena’s reputation to further personal agendas or interests, and nobody should use their position or title to speak for athena on a particular issue or agenda item, unless they have been expressly authorized to do so. athena complies with all applicable fair labor practices, child labor, age appropriate work, minimum wage, working hours, and human rights laws. athena also provides a safe and healthy working environment everywhere we operate. We are all expected to report any violence, threats, destruction of Company property, or other dangerous conditions we become aware of.

code ofconduct

TTreat each other with dignity and respect.

IMMEDIATELY REPORTany instance of harassment or discrimination they witness or learn of.

MODEL THE BEHAVIOR THEY WANTfrom their team.

PARTICIPATE IN THE DIALOGUEby engaging directly and being open to suggestions and new ideas.

TAKE INITIATIVEby finding new ways to enhance our diversity and transform ideas into actions.by finding new ways to enhance our diversity and transform ideas into actions

KEY TAKEAWAYTTAAKKEEAAWWWEEY WAAYTAAKKEAAEY T WWAA

TREAT OTHERS in the same manner you wish to be treated.

BE OPEN MINDED and do not dismiss ideas or suggestions simply because they differ from your own beliefs.

IMMEDIATELY REPORT to your manager, employee relations, HR, or Compliance any situation where you believe you are being treated unfairly, or see others that are being treated unfairly.


expected to…FOR MORE INFORMATION:

G-111 Harassment and Discrimination Policyathenahealth Conference and Event Code of ConductClient Event Escalation Protocol


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WE ARE HONEST AND RESPONSIBLE WITH ATHENA’S MONEY AND RESOURCESWe are all trusted and expected to be fiscally responsible: don’t steal; don’t lie; don’t cheat. We must all comply with the Company’s financial and accounting policies and always exercise good judgment to get fair value for athena when spending Company money.

All athenistas are expected to keep complete and accurate financial records of all expenditures and business transactions, submit accurate and complete expense reports, and comply with Company policies when it comes to spending athena’s resources. Falsifying, altering, or mischaracterizing Company expenditures or reimbursement submissions is never acceptable.

code ofconduct

Be honest and responsiblewith athena’s money and resources.

pp

SET CLEAR GUIDELINESestablish expectations for how Company funds should be spent.

BE PRESENTcritically review and understand how their budget is being used.

PRIORITIZEensure resources are spent on the most immediate and practical needs.

KEY TAKEAWAYY TTAAAKKEEAAWWKEY WAAYTAAAKKEEAAEYY T WWWA

NEVER FALSIFY OR MISREPRESENT EXPENSES on a reimbursement submission or in connection with a business transaction.

ENSURE YOU ARE GETTING FAIR VALUE for athena when spending Company money or resources, and only spend to further athena’s legitimate interests.


expected to…


G-104 Records Management and Communications ToolsC-500 Travel and Expense PolicyG-107 Business Payments and Gifts Policy C-205 Anti-Bribery Policy


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WE ARE REFRESHINGLY CANDIDWe are all responsible for maintaining our culture of integrity. That includes reporting concerns if you are not sure what the right thing to do is or if you believe someone may be doing something improper. athena takes all concerns or reports of potential misconduct seriously and treats everyone involved in the process with dignity and respect. Concerns or reports will be promptly and thoroughly reviewed by the appropriate teams. As part of that, all employees are required to participate in and cooperate

with any investigation when asked to do so. athena will not permit retaliation against anyone for making a good faith report of potential misconductor participating in a related investigation.

Those found to have engaged in misconduct or inappropriate behavior will be subject to discipline up to and including termination of employment. Other than termination, disciplinary action may include impacts to compensation, performance reviews, personnel record, cohort level, or could result in the employee being suspended or placed on leave.

code ofconduct

Be refreshingly candid.

BE AWARE OF THE THINGS THEIR TEAMS ARE DOINGLeaders are not “big brother,” but they are often in

the best position to identify misconduct.

BE PRESENT AND ESCALATE ISSUES APPROPRIATELYwhen they should properly be addressed by

Legal, Compliance, Employee Relations, or other teams.

ENGAGE AND FOLLOW DIRECTIONSfrom those leading an investigation into potential misconduct.

KEY TAKEAWAY

PROMPTLY REPORT any inappropriate behavior you witnessor become aware of.

PARTICIPATE COOPERATIVELY with internal investigations when called upon and only provide truthful and complete information.

NEVER OBSTRUCT an investigation or do anything in an attempt to conceal the truth.

MAINTAIN CONFIDENTIALITY at all times in connection with internal investigations.


expected to…

HOW TO REACH OUT WITH A QUESTION, ISSUE, OR CONCERN:

To report concerns anonymously 800-910-6732https://www.mycompliancereport.com/report.asp?fid=11&cid=ath&rpt=1

mailto:[email protected]



https://www.mycompliancereport.com/report.asp?fid=11&cid=ath&rpt=1

code of conduct - athenahealth · code conduct 2019 page 3 at athena, we aspire to a culture that...

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