HUMAN RESOURCES

Have you read Hurley’s Corporate Compliance Plan?

Do you know what to report and to whom to report it?

Every employee at Hurley has a responsibility to make sure they are doing their part to maintain compliance by following proper procedures and adhering to regulatory compliance policies. The Code of Conduct is a tool that can help you. The Corporate Compliance Plan (“Plan”) outlines Hurley Medical Center’s commitment to compliance and how to report an issue.

The Code of Conduct addresses the laws and regulations that we must be in compliance with. Ignorance of the law does not excuse either Hurley Medical Center or its employees and other representatives from an obligation for full compliance. Those laws include the False Claims Act, the Anti-Kickback Statute, the Stark Law, Occupational Safety and Health Administration laws (OSHA), and more.

The Plan also addresses the process for reporting potential violations of laws, regulations, policies and procedures. If you believe that some conduct involving Hurley Medical Center, its employees, agents, or representatives does not comply with the Code of Conduct, it is your responsibility to report it. Use the normal chain of command and report your concerns to your immediate supervisor, manager or department head. If you are uncomfortable reporting your concerns to your chain of command, you may contact any of the following:

• Your Administrator • Your Vice President • Human Resources • Your Union Representative • Labor Relations (810) 262-6580 or (810) 262-6314 • Corporate Compliance Officer (810) 262-9890 • Corporate Compliance Hotline (866) 835-0555 – The hotline is staffed by an independent hotline service. Reports may be made anonymously

The Code of Conduct prohibits retribution/ retaliation for reporting issues related to compliance. An employee's job status, working conditions or employment relationship with the Medical Center will not be jeopardized if he or she reports issues covered by the Plan or Code of Conduct or any other related concerns in good faith. Refer to the Hurley Medical Center Standard Practice # 0011 for additional information.

In summary: • Review and understand the Corporate Compliance Plan. It is located on the Hurley Intranet under Employee Resources\General Employee Resources\ Corporate Compliance Plan • Review and follow Code of Conduct. It is located on the Hurley Intranet under Employee Resources\General Employee Resources\Hurley Code of Conduct. • Conduct all of your work at Hurley in an honest and responsible manner • Ask questions when you are uncertain regarding what to do • Report concerns to your chain of command, or through the compliance hotline when something doesn’t seem right

Shellie Shue is the Corporate Compliance Officer. She can be reached at sshue1@hurleymc.com or 810.262.9890