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Procurement Ethics & Compliance

We maintain the highest ethical and business standards in our dealings with suppliers. We use established guidelines for all our procurement activities. We maintain a strict code of conduct, with ethical behavior required of all procurement professionals.

All vendors that conduct business with us are required to adhere to the Highmark Health Third Party Code of Business Conduct.

Principles:

• Integrity in your decisions and actions
• Value for your employer
• Loyalty to your profession

Standards:

1. Perceived impropriety. Prevent the intent and appearance of unethical or compromising conduct in relationships, actions and communications.
2. Conflicts of interest. Ensure that any personal, business or other activity does not conflict with the lawful interests of your employer.
3. Issues of influence. Avoid behaviors or actions that may negatively influence, or appear to influence, supply management decisions.
4. Responsibilities to your employer. Uphold fiduciary and other responsibilities using reasonable care and granted authority to deliver value to your employer.
5. Supplier and customer relationships. Promote positive supplier and customer relationships.
6. Sustainability and social responsibility. Champion social responsibility and sustainability practices in supply management.
7. Confidential and proprietary information. Protect confidential and proprietary information.
8. Reciprocity. Avoid improper reciprocal agreements.
9. Applicable laws, regulations and trade agreements. Know and obey the letter and spirit of laws, regulations and trade agreements applicable to supply management.
10. Professional competence. Develop skills, expand knowledge and conduct business that demonstrates competence and promotes the supply management profession.

Published here with permission from the Institute for Supply Management.

Highmark Health First Tier, Downstream, and Related Entity Handbook and General Compliance Training

For more than 75 years, Highmark (Highmark) has served its community with integrity, and is committed to maintaining the highest standards. In today's business and legal environments, acting ethically, lawfully and with integrity is the only way to operate; it differentiates a company from its competition as an organization that can be trusted.

Highmark recognizes that Third Parties are independent entities and their cultural environments may be different from Highmark; however, Third Parties play a critical role in Highmark's success and Highmark strives to conduct business with those who share similar values. To that end, we count on our Third Parties to preserve and strengthen our long-standing tradition as an ethical and compliant organization.

Third parties have additional obligations when they are involved in work that relates to the contracts we hold with the Centers for Medicare & Medicaid Services (CMS), to provide Medicare Advantage (Part C) and Medicare Prescription Drug (Part D) Plans. Annually, CMS requires Highmark to ensure that its Third Parties, identified as First Tier, Downstream or Related Entities (FDRs), meet compliance program requirements. The Highmark Health First Tier, Downstream, and Related Entity Handbook and General Compliance Training packet contains important information on key elements of our compliance program along with your obligations and FDR requirements.

The annual compliance program requirements include:

• General compliance and fraud, waste and abuse (FWA) training
• Code of conduct/compliance policies dissemination
• Office of Inspector General and General Services Administration Exclusion screenings
• Reporting mechanisms for potential fraud, waste, and abuse and potential non-compliance
• Delegate oversight

This packet contains pertinent information related to the requirements above. Failure to meet the FDR compliance requirements annually may affect your participation status.

Thank you for your partnership,

Melissa M. Anderson
Executive Vice President, Chief Auditor, and Compliance Officer
Highmark Health

Questions/Concerns

For compliance questions or concerns regarding this handbook, you can email the Highmark Compliance Department at gcvendor@highmark.com or call us at 1-800-985-1056.

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