GOODLAND REGIONAL MEDICAL CENTER CODE OF CONDUCT

TABLE OF CONTENTS

Introduction

Employees' Compliance-Related Responsibilities

Principle 1 - Patient Care and Treatment

Standard 1.1 Medical Decision Making

Standard 1.2 Patient Rights

Principle 2 - Compliance With Health Care Laws

Standard 2.1 Submission of Claims to Federal Health Care Programs
Standard 2.2 Anti-Kickback Statute

Standard 2.3 The Stark Law

Standard 2.4 Patient Inducements

Standard 2.5 HIPAA Administrative Simplification

Standard 2.6 Licensing Requirements

Standard 2.7 Controlled Substances

Standard 2.8 Safe Medical Devices Act

Standard 2.9 EMTALA

Standard 2.10 Mandatory Reporting Obligations

Standard 2.11 Government Inquiries and Investigations

Principle 3 - Compliance With Other Laws

Standard 3.1 Health, Safety, Environmental

Standard 3.2 Weapons, Illegal Drugs, and Alcohol

Standard 3.3 Discrimination and Inappropriate Conduct in the Workplace

Standard 3.4 Copyright

Standard 3.5 Record Retention

Standard 3.6 Kansas Open Meetings Act

Principle 4 - Confidentiality

Principle 5 - Business Ethics

Standard 5.1 Honest Communications

Standard 5.2 Advertising and Marketing

Standard 5.3 Patient Billing

Standard 5.4 Business Relationships

Principle 6 - Protection of Assets

Standard 6.1 Accuracy of Records 13

Standard 6.2 Internal Controls and Financial Reporting

Standard 6.3 Business Expenses

Standard 6.4 Personal Use of Corporate Assets

Standard 6.5 Use of Computers, Communications Systems, and Related
Equipment

Principle 7 - Conflicts of Interest

Standard 7.1 Outside Financial Relationships

Standard 7.2 Services for Competitors/Vendors





INTRODUCTION


As part of the Goodland Regional Medical Center Compliance Program, this Code of Conduct has been adopted by the Board of Directors to provide standards by which all GRMC employees and other persons affiliated with GRMC (including but not limited to members of the Board of Directors, volunteers, students, and trainees) shall conduct themselves to protect and promote organization-wide integrity and enhance GRMC's ability to achieve its mission.

Adherence to this Code of Conduct is a condition of continued employment for all employees. An employee's failure to abide by this Code of Conduct may lead to disciplinary action. For alleged violations of the Code of Conduct, GRMC shall weigh relevant facts and circumstances, including, but not limited to, the extent to which the behavior was contrary to the express language or general intent of the Code of Conduct, the egregiousness of the behavior, the Employee's history with the organization, and other factors which GRMC deems relevant. Discipline for failure to abide by the Code of Conduct may, in GRMC's sole discretion, range from oral correction to termination.

With respect to those persons who are not employees, adherence to this Code of Conduct is a condition of such persons' continued relationship with GRMC. Such person's failure to abide by this Code of Conduct may, in GRMC's sole discretion, lead to an alteration of the terms or discontinuation of such relationship.

GRMC has developed specific policies and procedures implementing the principles and standards contained in this Code of Conduct, and employees are expected to be knowledgeable of and comply with those policies and procedures. To the extent that any policy or procedure is inconsistent with the principles and standards contained herein, that policy or procedure is superseded by this Code of Conduct.

GRMC's Risk Manager also serves as the Compliance Officer. The Compliance Officer has overall responsibility for the operations of GRMC's Compliance Program. Any questions concerning the provisions of this Code of Conduct should be directed to the Compliance Officer.

Nothing in this Code of Conduct is intended to nor shall be construed as providing any additional employment or contract rights to any employee or other person.

This Code of Conduct is a living document, and shall be revised on an annual basis to coincide with annual employee training.

EMPLOYEES' COMPLIANCE RESPONSIBILITIES


GRMC requires every employee to comply with all applicable legal and ethical obligations in the performance of his/her job duties. In addition, GRMC expects every employee to take an active role in detecting and correcting activities that potentially violate applicable laws and regulations. Each employee must do the following:


LEARN

First, every employee shall participate fully in all educational programs concerning compliance-related issues. This includes active attendance at in-service and departmental meetings at which such issues are addressed, as well as thoughtful review of written materials provided to employees.

ASK

Second, any employee who has a question concerning a compliance-related issue shall seek assistance from an appropriate member of GRMC's administrative team.

REPORT

Third, any employee who suspects inappropriate conduct shall report such activities to an appropriate member of GRMC's management team.

COOPERATE

Fourth, every employee shall cooperate fully with any internal investigation concerning alleged non-compliance and any remedial measures taken to correct non-compliance.

Employees shall be evaluated for compliance with these obligations. Failure to perform these job responsibilities shall be a basis for discipline up to and including termination.

An employee seeking an answer to a compliance-related question or wanting to report a suspected incident of non-compliance should contact one of the following:

His or her supervisor

GRMC's Compliance Officer (Mary Ann Elliott) 785-890-6093

GRMC's Compliance Hotline which is a confidential outside voicemail [785-890-7392]

GRMC's web site and go to the employee section. Fill out the Compliance concern form which is password protected and available only to the Compliance Officer

Any Employee wishing to report anonymously to the listed telephone number must dial a "9" to access an outside line (if calling from GRMC-owned facility), then dial the number indicated above. Any reports sent to the internet e-mail address will show the address of the transmitting computer. An employee should not report a known or suspected violation by internet e-mail if complete anonymity is desired. GRMC shall make reasonable efforts to protect the anonymity of the person making such a report.

Some provisions of this Code of Conduct direct an employee to contact the Compliance Officer (which one can do by communicating directly with the Compliance Officer or calling the Compliance Hotline) with respect to questions or concerns relating to certain matters. These particular matters are of critical importance to GRMC, and therefore these concerns should be handled directly by the Compliance Officer. If any employee receives a question or concern relating to these matters from another employee, that employee should communicate such information to the Compliance Officer as soon as possible.

GRMC shall not tolerate retaliation against any employee who, in good faith, raises questions concerning legal compliance and/or reports any suspected incident of non-compliance. All such information reported by an employee shall be kept confidential to the extent confidentiality is possible throughout any resulting investigation.


PRINCIPLE 1 - PATIENT CARE AND TREATMENT


GRMC shall treat all patients with respect and dignity and provide care and treatment that is both necessary and appropriate. Clinical care shall be based on identified patient healthcare needs, not organization economics.

Standard 1.1 - Medical Decision Making

GRMC shall use standard clinical criteria to determine whether to treat an individual with specific interventions. Clinical decisions, including tests, treatments, and other interventions, shall be based on identified patient needs, and shall not in any way be based on the manner in which GRMC compensates or shares financial risk with its leaders, managers, clinical staff, or licensed practitioners.

Standard 1.2 - Patient Rights

All employees shall respect patient rights in the performance of their job duties. Patients and their representatives shall be accorded appropriate confidentiality, privacy, security and protective services, opportunity for resolution of complaints, and pastoral counseling.


PRINCIPLE 2 - COMPLIANCE WITH HEALTH CARE LAWS


GRMC shall conduct its operations in compliance with state and federal laws and regulations specific to health care providers. GRMC shall cooperate with any government inquiry concerning its compliance with such rules.

The health care industry is one of the most highly regulated segments of the U.S. economy. While employees are not expected to have expert knowledge of all legal and regulatory requirements that may apply to their work, each employee must be sensitive to relevant legal issues. Any employee who is uncertain about any given situation should seek guidance from an appropriate member of management.

The following standards summarize some of the important legal requirements applicable to health care providers and the impact of those requirements on GRMC's operations. Employees must comply with all laws and regulations in the performance of their job duties, regardless of whether they are specifically addressed here.

Standard 2.1 - Submission of Claims to Federal Health Care Programs.

The federal False Claims Act prohibits the submission of false, fraudulent, or misleading claims to any government entity (e.g., Medicare, Medicaid, TriCare) including, but not limited to, the following: (1) claims for services not rendered; (2) claims which characterize the service differently than the service actually rendered; (2) claims for services that were not medically necessary; and (4) claims which do not otherwise comply with applicable program or contractual requirements.

All employees involved in the delivery of patient care shall be responsible for producing and maintaining complete and accurate documentation in the appropriate medical record and submitting complete and accurate charges for all medical goods and services provided to patients. All employees involved in coding and billing shall prepare and submit claims in compliance with all applicable requirements. Any employee who discovers inaccuracies in claims submitted to any payor shall immediately communicate this information to the Compliance Officer so that appropriate action may be taken.

Standard 2.2 - Anti-Kickback Statute

The federal Anti-Kickback Statute prohibits payments to physicians and health care facilities for the referral of Medicare and Medicaid business. Courts have broadly construed this law to include virtually anything of value given to an individual or entity if one purpose of the remuneration is to influence the recipient's reason or judgment relating to referrals. Many states have similar laws, including prohibitions on fee splitting and patient brokering.

GRMC does not provide remuneration (in the form of cash payment, gift, contribution, or otherwise) in exchange for referrals or as an inducement for referrals. GRMC accepts patient referrals and admissions based solely on the patient's clinical needs and GRMC's ability to render the needed services. GRMC does not pay or offer to pay anyone -- colleagues, physicians, or other persons -- for referral of patients.

GRMC does not accept payments for referrals that it makes. No employee shall solicit or receive anything of value, directly or indirectly, in exchange for the referral of patients. Similarly, when making patient referrals to another healthcare provider, GRMC shall not take into account the volume or value of referrals that the provider has made (or may make) to GRMC.

Any transaction involving another health care provider, whether formal or informal, must be scrutinized for compliance with the Anti-Kickback Statute. All such transactions shall be based on fair market value for the goods or services provided. Any employee who has any concern about the propriety of GRMC's relationship with another health care provider should raise that matter with the Compliance Officer so that appropriate action may be taken.

Standard 2.3 - The Stark Law

The federal Stark law (named after the sponsor of the legislation) prohibits a physician from making referrals to entities furnishing certain designated health services if the physician owns an interest in the entity or has a financial relationship with the entity, unless the ownership interest or financial relationship meets certain limited exceptions. GRMC shall comply with the Stark law in all of its financial arrangements with physicians. Any transaction between GRMC and a referring physician should be reviewed in advance by the Chief Executive Officer.

Standard 2.4 - Patient Inducements

Federal law also prohibits GRMC from offering or transferring anything of value to any person eligible for federal health care benefits if GRMC knows or should know such inducement would cause the eligible person to choose to receive federally reimbursable items or services from GRMC except as specifically permitted by law. In light of this prohibition, no employee acting on behalf of GRMC shall give anything of value to any patient or prospective patient unless such gift has been reviewed and approved in writing by the Compliance Officer.

GRMC shall not waive deductibles, co-payments, or otherwise provide financial benefits to patients in return for business. GRMC shall not permit professional discounts, and courtesy discounts are permitted only in limited circumstances. Under certain circumstances, GRMC may provide appropriate financial accommodations to patients based solely on established policies and procedures. All patient account balances shall be resolved using GRMC documented collection policies and procedures.

Standard 2.5 - HIPAA Administrative Simplification

GRMC shall devote necessary resources to ensure compliance with the federal regulations concerning the security and privacy of protected health information. Employees shall receive appropriate training to enable them to perform their job duties in compliance with these legal requirements.

Standard 2.6 - Licensing Requirements

GRMC shall remain in compliance with all state and federal licensing requirements for health care facilities, including but not limited to the applicable Medicare Conditions of Participation for Critical Access Hospitals. Any employee who is licensed by a state agency (e.g., registered nurse, physical therapist) shall be personally responsible for maintaining such licensure (although GRMC may reimburse an employee for certain licensing fees).

Standard 2.7 - Controlled Substances

Some employees have access to prescription drugs, controlled substances, and other medical supplies. The use of these items is governed by government regulations and must be administered pursuant to physician order. It is extremely important that these items be handled properly by authorized individuals to minimize risk to patients and GRMC. If an employee becomes aware of the diversion of drugs from GRMC, the employee shall report the matter immediately to the Compliance Officer.

Standard 2.8 - Safe Medical Devices Act

GRMC is committed to participation in this governmental program to prevent patient injury from medical devices by reporting appropriate events to the device manufacturer and/or the Food and Drug Administration. Any event in which a patient is injured by a device should be reported to GRMC's Risk Manager, and such reports shall be handled pursuant to established policies and procedures.

Standard 2.9 - EMTALA

GRMC shall comply with the requirements of the Emergency Medical Treatment and Labor Act ("EMTALA") in providing medical screening examinations and stabilizing treatment to all patients, regardless of ability to pay. GRMC has developed specific policies and procedures concerning its obligations under EMTALA, and employees shall be familiar with and adhere to those policies and procedures.

When a person presents at a dedicated emergency department for a non-scheduled visit and requests medical examination and/or treatment, GRMC shall provide such person with an appropriate medical screening examination to determine whether the person has an emergency medical condition, regardless of the person's ability to pay.

If a patient is diagnosed as having an emergency medical condition, GRMC shall provide medical treatment within its capabilities to stabilize the medical condition. If GRMC does not have the capabilities to stabilize the patient, it shall make an appropriate transfer to a facility having such capabilities. GRMC shall not discharge an unstable patient with an emergency medical condition unless such person refuses medical examination and/or treatment.

GRMC shall not refuse to accept an appropriate transfer of an individual with an emergency medical condition who requires specialized capabilities or facilities if GRMC has the capacity to treat the individual.

Standard 2.10 - Mandatory Reporting Obligations

Numerous federal and state laws and regulations require GRMC and/or its employees to disclose certain information to specified government officials. For example, health care providers must report suspected incidents of child abuse to the Kansas Department of Social and Rehabilitation Services. Any employee with a legal obligation to report certain information to a government agency shall do so in a timely and complete manner.

Standard 2.11 - Government Inquiries and Investigations

Health care providers often are the subjects of government investigations targeting alleged billing improprieties or violations of the aforementioned laws. The mere fact a government agent makes inquiries concerning GRMC's practices does not mean GRMC has engaged in any wrongdoing. All employees shall be familiar with and comply with GRMC's policy and procedure concerning the proper handling of government inquiries and investigations.


PRINCIPLE 3 - COMPLIANCE WITH OTHER LAWS


GRMC shall conduct its operations in compliance with state and federal laws and regulations applicable to businesses and employers.

In addition to those laws and regulations applicable to health care providers, GRMC also must comply with those legal requirements applicable to most businesses and employers. The following standards summarize some, but not all, of those legal requirements and the impact of those requirements on GRMC's operations. Employees must comply with all laws and regulations in the performance of their job duties, regardless of whether they are specifically addressed here.

Standard 3.1 - Health, Safety, and Environmental

Employees shall be familiar with all applicable health and safety laws and regulations, and shall act in compliance with the letter and spirit of those requirements at all times. It is the policy of GRMC to manage and operate its business in the manner which protects the health and safety of all employees and respects the environment and conserves natural resources. Employees shall strive to utilize resources appropriately and efficiently and dispose of all waste in accordance with applicable laws and regulations.

Standard 3.2 - Weapons, Drugs, and Alcohol

No employee shall bring any weapon of any kind into the workplace. GRMC prohibits the use, sale, dispensing, or possession of illegal drugs by its employees, whether on or off the premises of GRMC. Illegal drugs include prescription drugs not dispensed or used pursuant to a properly authorized prescription and over-the-counter drugs used in a manner inconsistent with package directions. No employee shall report to work under the influence of illegal drugs or alcohol, nor shall any employee report to work with an impairment resulting from the use of over-the-counter or prescription drugs. An employee may be asked to submit to a drug test at any time deemed appropriate by GRMC and permitted by law.

Standard 3.3 - Discrimination and Inappropriate Conduct in the Workplace

GRMC believes that the fair and equitable treatment of patients, employees, and other persons is critical to fulfilling its vision and goals.

It is a policy of GRMC to provide care and treatment to patients without regard to the race, color, religion, creed, sex, national origin, age, or disability of such person, or any other classification prohibited by law.

It is a policy of GRMC to recruit, hire, train, promote, assign, transfer, layoff, recall, and terminate employees based on their own ability, achievement, experience, and conduct without regard to race, color, religion, creed, sex, national origin, age, disability, or any other classification prohibited by law.

No form of harassment or discrimination on the basis of sex, race, color, age, religion, creed, national origin, disability, or any other classification prohibited by law shall be permitted. Employees shall not engage in inappropriate conduct or disruptive conduct in the workplace. Employees shall report any harassment, discrimination, inappropriate conduct, or disruptive conduct in the workplace of which they are aware to the Human Resources Department. Allegations of harassment, discrimination, inappropriate conduct, or disruptive conduct shall be investigated promptly by the Human Resources Department.

Standard 3.4 - Copyright

Copyrighted materials such as books, magazines, computer software, and recordings are protected by federal law. Unauthorized copying may constitute copyright violation. Copying is allowed for educational and research purposes. An employee who desires to reproduce copyrighted material should receive permission from his/her supervisor prior to doing so. Use of any computer software without an appropriate license is strictly prohibited.

Standard 3.5 - Record Retention

GRMC is required by law to maintain certain types of medical and business records, usually for a specified period of time. Failure to retain such documents for such minimum periods could subject GRMC to penalties and fines, cause the loss of rights, obstruct justice, place GRMC in contempt of court, or put GRMC at a serious disadvantage in litigation. GRMC has established controls to assure retention for required periods and timely destruction of records. Employees shall comply with the records retention and destruction schedule for the area in which they work. GRMC shall permit public access to its records in compliance with the requirements of the Kansas Open Records Act.

Standard 3.6 - Kansas Open Meetings Act

All meetings of GRMC's governing body (including committee meetings) shall be conducted in accordance with the Kansas Open Meetings Act.


PRINCIPLE 4 - CONFIDENTIALITY


All employees shall execute and abide by the GRMC Confidentiality Agreement upon signing.


PRINCIPLE 5 - BUSINESS ETHICS


In furtherance of GRMC's commitment to the highest standards of business ethics and integrity, employees shall accurately and honestly represent GRMC and shall not engage in any activity or scheme intended to defraud anyone of money, property, or honest services.

Standard 5.1 - Honest Communication

GRMC requires candor and honesty from employees in the performance of their responsibilities. No employee shall make false or misleading statements to any person or entity, including other employees, concerning any aspect of GRMC's operations.

Standard 5.2 - Advertising and Marketing

GRMC shall market and advertise its services fairly, honestly, and in a non-deceptive manner, stressing their value and merits. Employees shall not use tactics that misrepresent GRMC or that unfairly undermine the products and services of a competitor. This includes the use of disparaging comments or innuendoes.

Standard 5.3 - Patient Billings

The importance of submitting proper claims to federal health care programs is addressed in Standard 2.1. The same standards of conduct apply with respect to claims for services provided to persons with private insurance and self-pay patients.

GRMC shall strive to comply with all contractual requirements for private payors. GRMC shall provide complete and accurate responses to all reasonable inquiries concerning patient bills. GRMC shall utilize established policies and procedures to resolve any dispute concerning such bills.

GRMC shall cooperate fully with any duly authorized third-party audit of patient accounts. GRMC shall respond promptly to any reasonable request for information from any such auditor in compliance with established policies and procedures.

Standard 5.4 - Business Relationships

Business transactions with vendors, contractors, and other third parties shall be transacted free from offers or solicitation of gifts and favors or other improper inducements in exchange for influence or assistance in a transaction. All employees shall be familiar with and comply with GRMC's policy and procedure concerning business inducements.

PRINCIPLE 6 - PROTECTION OF ASSETS


All employees shall strive to preserve and protect the corporation's assets by making prudent and effective use of GRMC's resources and properly and accurately reporting its financial condition.

Standard 6.1 - Accuracy of Records

All employees are responsible for the integrity and accuracy of GRMC's documents and records (including paper documents such as letters and memos, computer-based information such as e-mail or computer files on disk or tape, and any other medium that contains information about GRMC or its activities), not only to comply with regulatory and legal requirements but also to ensure that records are available to defend business practices and actions. No employee shall alter, falsify, or purposefully omit information on any record or document. Corrections to any record or document shall be made pursuant to established policies and procedures.

Standard 6.2 - Internal Controls and Financial Reporting

No undisclosed or unrecorded funds or assets may be established. GRMC shall maintain a system of internal controls to provide reasonable assurances that all transactions are executed in accordance with management's authorization and are recorded in a proper manner so as to maintain accountability of the organization's assets. Employees shall comply with these controls. All financial information shall reflect actual transactions and conform to generally accepted accounting principles. No undisclosed or unrecorded funds or assets shall be established. Any employee who questions GRMC's compliance with internal controls or the accuracy of GRMC's financial reports shall report such concerns to the Compliance Officer.

Standard 6.3 - Business Expenses

If an employee is authorized to incur business expenses on behalf of GRMC, such employee is responsible for the accurate and timely reporting of such expenses. All expenditures must be in accordance with applicable policies.

Standard 6.4 - Personal Use of Corporate Assets

All employees are expected to refrain from using GRMC's assets for personal use. All operations of the organization shall be conducted in the manner designed to further GRMC's interests rather than the personal interests of an individual employee. Employees are prohibited from the unauthorized use or taking of GRMC's equipment, supplies, materials, or services. Prior to engaging in any activity on company time which will result in remuneration to the employee or the use of GRMC's equipment, supplies, materials or services for personal or non-work related purposes, employees shall obtain approval from GRMC's Chief Executive Officer.

Standard 6.5 - Use of Computers, Communications Systems, and Related Equipment

GRMC has implemented and maintains a number of safeguards to protect the confidentiality, integrity, and availability of information created, maintained, or received in electronic form. Employees shall be aware of and adhere to such safeguards in performing their job duties. Employees shall report any suspected breach of such security measures.

E-mail and voice-mail messages reflect the image of GRMC. Employees should compose and deliver such messages in a professional manner that is similar to messages sent on GRMC letterhead. Employees should keep in mind that electronic files (and even voice mail, if recoverable) may be subject to discovery and may subsequently be used in litigation or investigations involving GRMC or an employee.

All computers, communications systems, and related equipment (including, but not limited to, computer files and drives, electronic mail, intranet service, internet access, and voice mail) are the property of GRMC and are to be primarily used for business purposes. Highly limited reasonable personal use of computers, communications systems, and related equipment is permitted; however, an employee should assume that such communications are not private.

GRMC reserves the right to periodically access, monitor, print, copy, and disclose the contents of computer files and drives and e-mail and voice mail messages. Such action taken may only be done with the prior approval of GRMC's Security Officer.

Employees shall not use GRMC computers, communication systems, or related equipment to send or receive any message or download or retrieve any materials (video or audio) that could be considered inappropriate or illegal under state or federal law. GRMC computers, communication systems, or related equipment shall not be used to store, transmit, or receive messages or materials (video or audio) having language or images that may reasonably be considered offensive, harassing, demeaning, or disruptive to any employee. Such prohibited conduct includes, but is not limited to, sexually explicit or derogatory comments or images, gender-specific comments, racial epithets and slurs, or any comments, jokes, or images that would offend someone or create a hostile work environment based on his/her race, color, sex, religion, creed, national origin, age, or disability.

It is further prohibited to send or receive messages or materials on GRMC computers, communication systems, or related equipment in a way which includes the use of profane or offensive language or, in the judgment of management, is determined to be profane, demeaning, insulting, disruptive, threatening, intimidating, violent, defamatory, harassing, embarrassing, insubordinate, or otherwise inappropriate or unprofessional. Finally, GRMC computers and communication systems, or related equipment shall not be used to conduct a job search or open misaddressed mail.


PRINCIPLE 7 - CONFLICTS OF INTEREST


Employees owe a duty of undivided and unqualified loyalty to the organization. Employees shall not use their positions to profit personally or to assist others in profiting in any way at the expense of the organization.

A conflict of interest may occur if an employee's outside activities, personal financial interests, or other personal interests influence or appear to influence his/her ability to make objective decisions in performing his/her job responsibilities. A conflict of interest may also exist if the demands of any outside activities hinder or distract an employee from the performance of his/her job responsibilities. Every employee is obligated to ensure he/she remains free of any such conflict of interest. GRMC's directors and officers are subject to a separate policy concerning conflicts of interest.

Standard 7.1 - Outside Financial Interests

While not all inclusive, the following are examples of the types of activities by an employee, or household member of such person, which might cause conflicts of interest. Employees, therefore, must refrain from engaging in these and similar activities.

1. Ownership in or employment by any outside concern which does business with GRMC. This does not apply to stock or other investments held in a publicly held corporation, provided the value of the stock or other investments does not exceed 5 percent of the corporation's stock. GRMC may, following a review of the relevant facts, permit ownership interests which exceed this amount if management concludes such ownership interests will not adversely impact GRMC's business interest or the judgment of the covered person.

2. Conduct of any business not on behalf of GRMC with any vendor, supplier, contractor, or agency, or any of their officers or employees.

3. Representation of GRMC by an employee in any transaction in which he or she or a household member has a substantial personal interest.

4. Disclosure or use of confidential, special, or inside information of or about GRMC, particularly for personal profit or advantage of the member of the workplace or a household member.

5. Competition with GRMC by an employee, directly or indirectly, in the purchase, sale, or ownership of property or property rights or interests or business investment opportunities.

Standard 7.2 - Services for Competitors/Vendors

No employee shall perform work, consult with, or render services for any competitor of GRMC or for any organization with which GRMC does business or which seeks to do business with GRMC outside of the normal course of his/her employment with GRMC without the approval of the employee's supervisor. Nor shall any such employee be a director, officer, or consultant of such an organization, nor permit his/her name to be used in any fashion that would tend to indicate a business connection with such organization.

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