Ethics and Compliance

Health Care Service Corporation (HCSC) employees must conduct Company business ethically, with integrity, and according to all applicable laws, regulations and contractual obligations. To accomplish this goal, we must follow the principles of our Compliance Program as well as our Code of Ethics and Conduct (the "Code").

Maintaining ethical standards is in everyone's interest and it is each employee’s responsibility to be familiar with the Company Code, policies, procedures and corporate standards. Claims of ignorance, good intentions or using poor judgment will not be accepted as excuses for non-compliance. Violations of the Code, law, Company policies, procedures and corporate standards (or failure to report such violations) will result in disciplinary action up to and including termination.

Likewise, supervisors have a special responsibility to create and sustain a work environment in which employees know that ethical and legal behavior is expected of them. Each supervisor is responsible for serving as an example and making sure that their employees understand and apply ethical standards.

All suspected violations are taken seriously and investigated. The Ethics & Compliance Department may enlist other areas of the Company to review the information supplied or conduct their own investigation.

Policies, Procedures and Corporate Standards

Health Care Service Corporation (HCSC) is founded on basic principles of good business behavior and each are applicable to all employees including its Board of Directors. Among these principles is a commitment to comply with the laws and regulations that govern our business as well as the operations of our majority-owned subsidiaries. This compliance reinforces our Company’s status as a responsible corporate citizen. It also assures our customers, providers, employees and the general public of our honesty and integrity.

HCSC's policy is to deter the occurrence of unethical or unlawful behavior, to detect as early as possible such behavior whenever it occurs, to appropriately disclose such behavior to authorities and to actively and fully cooperate in any investigation or regulatory inquiry.

Under certain contracts, the Company and/or its subsidiaries provides services to various agencies of federal, state or local governments as either a prime contractor or a subcontractor. HCSC and its subsidiaries are committed to full and comprehensive compliance with all of its contractual obligations regarding these services. This includes, but is not limited to, adopting specific policies and procedures for all employees that work on such contracts, providing appropriate training and resources and operating an effective compliance program in regards to such contracts.

Additional details about HCSC's policies, procedures and corporate standards can be found in our complete Code of Ethics and Conduct (the "Code").

Last Updated: Oct. 22, 2020