Business Code of Conduct

Business Code of Conduct

Mission, Vision and Values

Mission…

“To enable and empower individuals and families to live quality lives.”

Vision…

The Center will continue to involve consumers, families, program staff and other community leaders and neighbors in concerted efforts to:

• Improve the overall quality of services to persons served with mental illness, intellectual and developmental disabilities, and substance use disorders. Expand services to meet the needs of those with mental illness, intellectual and development disabilities, and substance use disorders who are unserved or underserved.
• Promote positive work environments in which staff and volunteers work with pride, integrity and commitment, and are valued for their individual worth and contribution.
• Promote effective leadership and management at all levels so as to improve services and earn public confidence and support.
• Improve public understanding of mental illness, intellectual and development disabilities, and substance use disorders, and of the Center’s responsibility and/or role to persons with these disabilities
• Build and support positive relationships with consumers, families, advocacy groups, higher education, other public agencies, and the private sector to better serve persons with mental illness, intellectual and development disabilities, and substance use disorders.
• Operate a financially healthy and stable organization to ensure a growing array of services to those persons we serve

Values…

• Individual Worth: the Center affirms that the individuals served share with all persons common human needs, rights, desires, dignity, and strengths. The Center celebrates cultural and individual diversity.
• Quality: The Center commits itself to the pursuit of excellence in everything it does.
• Integrity: The people of the Center believe that personal and professional integrity is the basis of public trust.
• Dedication: The Center takes pride in its commitment to public service and to the people it is privileged to serve.
• Innovation: The Center is committed to developing an environment that inspires and promotes innovation, fosters dynamic leadership, and rewards creativity among its staff, volunteers, and the people served.

I. Statement of Purpose.

Gulf Coast Center (Center) employees, contract providers and volunteers will exhibit behavior based on honesty, integrity and a sense of fairness. It is the responsibility of these individuals to maintain the highest standard of legal and ethical behavior. This includes complying with all local, state and federal laws and regulations designed to assure adequate and appropriate care and taking timely and responsive positive action to prevent or correct any improper or inappropriate acts. The Center’s Board of Trustees and Management are committed to providing avenues through which ethical issues may be raised, reviewed and resolved openly and honestly.

II. Ethical Standards.

The business conducted by the Gulf Coast Center will be delivered in an environment with the highest ethical, legal and professional standards. Honesty, integrity and impartiality will be demonstrated when dealing with Center customers, providers, vendors, regulators, competitors, community and employees. In addition, any individual who is professionally licensed shall adhere to the code of ethics of that profession. The Board of Trustees, employees, contract providers and volunteers will make every effort to avoid even the appearance of illegal, unethical or unprofessional conduct. (Policy reference 4.4)

III. Leadership Responsibilities.

While all Center employees, contract providers and volunteers are obligated to follow the Code of Conduct, we expect our leaders to set the example, to be in every respect a role model. They must ensure that those on their team have sufficient information to comply with laws, regulations and policies; as well as the resources to resolve ethical dilemmas. They must help to create a culture within the Center which promotes the highest standards of ethics and compliance. The culture must encourage everyone in the organization to share concerns when they arise. We must never sacrifice ethical and compliant behavior in the pursuit of business objectives.

IV. Conflict of Interest / Outside Business and Financial Interests.

A conflict of interest may occur if outside activities or personal interests influence or appear to influence objective decision making in the course of Center-related responsibilities and duties. A conflict may also exist if the demands of any outside activities hinder or distract your job performance or cause you to use Center resources for other than Center purposes. Employees and contract providers are expected to exhibit professional loyalty to the Center. Employees and contract providers are expected to avoid conflicts of interest and opportunities for personal gain for themselves individually, members of their immediate families and others which may impede their best judgment. (Policy reference 13.5)

The following are guidelines for Board of Trustees, employees and contract providers regarding interests outside of the business conducted by the Gulf Coast Center:

A. Employees, or members of their respective families and contract providers should not have substantial financial or business interest with a competitor, customer or supplier of Gulf Coast Center without first reviewing the nature of activity with the Center’s legal counsel.
B. Each employee’s employment should be his/her first business priority. Any other employment or business activity will be considered secondary and should not interfere with individual employee job performance and responsibilities. Approval for secondary employment requires the approval of the Center’s Executive Director. (Policy reference 13.51)

V. Gifts and Favors.

The following are expectations of employees, contract providers and volunteers (Policy references 13.55, 13.56):

A. Employees working under DSHS Substance Use Disorder guidelines and programs may not accept gifts of any kind.
B. In compliance with all applicable federal and state laws, Center employees may not accept or solicit any gift or benefit that one may reasonably believe was given to influence a decision(s) regarding care of an individual, to secure preferential treatment or regarding purchases, contracts or any discretionary decision concerning expenditure or use of Center assets. Under no circumstances may cash be accepted as a gift from an individual in services to a Center employee. Consumers seeking to make a cash donation may be advised to make the intended cash donation to a charitable organization (which may be the Center).

The following are not prohibited by this policy:
1. Token Gifts which are items with a value of less than $50, excluding cash or a negotiable instrument, if it was not given in exchange for any exercise of the employee’s duties. Therefore, commercially produced or purchased gifts to a Center employee by an individual in services or vendor shall not be accepted if the fair market value of the gift exceeds $50.00.
2. Gifts from family and close friends if there is an established independent relationship that is not related to status or work of the Center employee.
3. Gifts from other business associates with whom the Center employee has an independent business relationship that is not related to the employee’s duties at the Center.

VI. Compliance.

The following are guidelines for compliance with this Center’s Compliance Plan, including the Business Code of Conduct (Policy reference 5.4):

A. Employees, contract providers and volunteers are committed to complying with all federal and state laws and regulations, with an emphasis on preventing fraud and abuse.
B. Gulf Coast Center will conduct audits and other risk evaluations to monitor compliance and assist in the reduction of identified problem areas.
C. Gulf Coast Center will maintain processes to:

1. Detect Medicaid/Medicare or other third party payer compliance offenses;
2. Initiate corrective and preventive action;
3. Report to appropriate oversight authorities, both professional and regulatory, when appropriate; and
4. Address consequences for employees, contract providers and volunteers for failure to comply with standards, policies and procedures.

D. Employees, contract providers and our volunteers are committed to ensuring the privacy of our consumer/clients’ protected health information. We are committed to compliance with all privacy and security rules relating to the Health Insurance Portability and Accountability Act (HIPAA), along with other federal and state laws that are integral to matters of privacy, medical records, confidentiality of communications and identity theft protection of those we serve The Center shall maintain a process to monitor and detect flags for potential identity theft identity theft; appropriately notify those affected and/or those required to be notified by law; and initiate corrective action plans or improvement projects as appropriate.

VII. Accounting and Reporting.

It is Gulf Coast Center policy to maintain and submit accurate and honest records related to all billing or reporting, including Medicare and Medicaid, and to comply with all laws and regulations relating to Medicare or Medicaid. All employees who document any service shall do so honestly, describing the services actually rendered. Each employee and contract provider will ensure the integrity of the Center by accurately and truthfully recording all corporate information, accounting and operational data through strict adherence to established accounting and business procedures. (Policy reference 14.2)

VIII. Corporate Resources.

Each employee, contract provider, intern and volunteer is expected to use corporate resources economically and safeguard corporate assets at all times. Care should be taken to treat Center resources as if they were your own, or better. It is the responsibility of each employee, contract provider and volunteer to preserve the Center’s assets including time, materials, supplies, equipment, computers, electronic communications devices, and information. The Center’s assets are to be maintained for business related purposes. As a general rule, the personal use of any Center asset without the prior approval of your supervisor is prohibited. The occasional use of items such as copiers, fax machines, printers or facility phones for local personal calls, where the cost to the Center is insignificant, is permissible. The postage machine is never available to employees, contract staff, interns or volunteers for personal use. Specific policies/procedures should be referenced for proper use of other Center resources such as gasoline credit cards, Center vehicles, and Center issued electronic communications devices. Any community or charitable use of Center resources must be approved in advance by your supervisor. Any use of Center resources for personal financial gain unrelated to the organization’s business is prohibited. (Policy reference 13.41)

IX. Political Activities.

As good citizens, each employee and contract provider is encouraged to participate in the political process. The Gulf Coast Center must, however, ensure that employee and contract provider’s political activities and contributions do not appear to represent the opinion of the Gulf Coast Center. Individuals can support political candidates as they so choose using their own personal resources.

A. Only the members of the Center’s Board of Trustee’s may engage in attempting to influence decisions of state and local officials. Center staff are prohibited from lobbying on behalf of the Center.
B. Staff and Center Trustees can provide professional opinions, testimony, and input to local and state officials – including State Boards – when invited to participate by the official(s) or participating in political local forums.
C. Any and all expenses associated by Centers in an effort to inform or influence should come from unrestricted local funds.

X. Confidentiality.

Confidential information including Center strategies, operations and clinical data is a valuable asset. Each employee, contract provider and volunteer is expected to diligently safeguard all Gulf Coast Center records deemed confidential including information about Center consumers and their families; internal operations; and fellow employees and contract providers as described in Gulf Coast Center policy and/or federal and state law (including the Texas Open Records Act). (Policy 2.5, 9.3 & 13.54) Although you may use confidential information to perform your job, it must not be shared with others unless the individual(s) have a legitimate, within the limits of the law, need to know the information and have agreed to maintain confidentiality or you have a signed authorization for release signed by the person who can invoke the right. Employees may not access the confidential information of relatives, in-laws, friends or acquaintances unless there is both a legitimate need to know and appropriate procedures are followed. When or if your relationship with the Center ends for any reason, you are still bound to maintain the confidentiality of information viewed during your time with the Center.

XI. Employee Relations/Professional Conduct.

Each employee is expected to perform assigned tasks in a reliable and cooperative manner and treat each other with mutual respect, dignity and trust. Examples of prohibited behavior include:

A. Threatening or abusive behavior
B. Arguing
C. Fighting
D. Harassment

Each employee has the right to work in an environment free of harassment and disruptive behavior. Harassment will not be tolerated. Degrading or humiliating jokes, slurs, intimidation, or other harassing conduct is not acceptable in our
workplace. (Policy reference 13.61)

1. Harassment could be related to race, creed, color, sex, sexual orientation, national origin, ancestry, citizenship status, marital status, pregnancy, age, medical condition, handicap and/or disability.
2. Verbal or physical conduct of a sexual nature that interferes with an individual’s work performance or creates an intimidating, hostile, or offensive work environment has no place at The Gulf Coast Center.
3. As part of the Center’s commitment to staff safety, the Center has a No Weapons policy. Individuals who enter Center facilities and vehicles are banned from carrying weapons including guns, explosive materials, switch blades, and a host of other items deemed as weapons per the policy.

Each employee is expected to conduct themselves in a professional manner and maintain a professional and businesslike relationship with co-workers, supervisors and persons served. Examples of professional conduct include but are not limited to the following:

A. Appropriate dress (See Center Dress Code)
B. Punctuality in reporting to work
C. Answering and returning business calls in a timely manner
D. Limiting use of personal communication devices during work hours
E. Maintaining confidences by not repeating personal or privileged information
F. Completing assigned duties without dishonesty, fraud, deceit or misrepresentation

Although the Center is not concerned with conduct and actions of employers during non-work hours, off duty conduct may becomes a legitimate concern when it has the potential of impacting agency operations. Such off-duty conduct may result in appropriate disciplinary action against the employee concerned. Examples of off duty conduct which may have ramifications at work include inappropriate social media posts, illegal behavior, and other behavior and conduct that is in conflict with the Center’s mission, vision, and values.

XII. Customer Focus / Consumer Client Relations.

Because Center consumers/clients are the primary focus of every activity, each employee and contract provider will be committed to continually improving our products, services and cost competitiveness to meet the individual needs of Gulf Coast Center consumers.

All consumers are treated in a manner that preserves their dignity, respect, autonomy, self-esteem and civil rights. Each individual has the right to be involved in his/her own care. It is the responsibility of each employee and contract provider to ensure that consumers’/clients’ rights are protected. To that end, each employee and contract provider must familiarize themselves with consumer/client rights set forth in the policy and procedure manual and the rights protection handbook. Consumer/clients, or when appropriate the consumer/client’s LAR, shall be informed of their rights in advance of, during and upon discontinuation of care. The Center will maintain processes to support consumer/client rights in a collaborative manner which includes staff and others. These structures are based on policies and procedures, which make up the framework addressing both consumer/client care and organizational ethics issues. Additionally, the Center has established processes for prompt resolution of consumer/client complaints/grievances which include informing individuals of whom to contact regarding complaints, and informing individuals regarding the complaint resolution. Center employees, contract staff and volunteers will receive training about consumer/client rights in order to clearly understand their role in supporting them. (Policy references 2.1, 2.2, 2.5 & 2.6)

XIII. Controlled Substances.

To protect the interests of our employees and consumers/clients, we are committed to an alcohol and drug-free work environment. All employees must report for work free of the influence of alcohol and illegal drugs. Reporting to work under the influence of any illegal drug or alcohol; having an illegal drug in your system; or using, possessing, or selling illegal drugs while on Center property may result in immediate termination. We may use drug testing as a means of enforcing this policy. The illegal use or possession of any controlled substance is unacceptable and will not be tolerated. These acts are illegal and jeopardize the safety of employees, contract providers and consumers/clients; and reduce productivity, reliability and trustworthiness. (Policy references 13.65 & 13.69)

XIV. Reporting Misconduct.

To obtain guidance on an ethics or compliance issue or to report a suspected violation, you may choose from several options. We encourage the resolution of issues, including human resources-related issues at the program level whenever possible. It is an expected good practice, when you are comfortable with it and think it appropriate under the circumstances, to raise concerns first with your supervisor. If this is uncomfortable or inappropriate, another option is to discuss the situation with the Center’s Corporate Compliance Officer or Director of Legal Services, as appropriate. The Center will make every effort to maintain, within the limits of the law, the confidentiality of the identity of any individual who reports possible misconduct. There will be no retribution or discipline for anyone who reports a possible violation in good faith. Any colleague who deliberately makes a false accusation with the purpose of harming or retaliating against another employee, contract provider or volunteer will be subject to disciplinary action.

The following are obligations for reporting misconduct:
A. Each employee, contract provider and volunteer is responsible for bringing to the attention of his/her Gulf Coast Center supervisor any situation that appears to be in violation of this Business Code of Conduct. Whether a violation is the result of an innocent mistake or planning and intent, it is important that all employees take responsibility for bringing the violation to the attention of someone who can correct the situation.
B. Supervisors will suggest appropriate action and contact the Gulf Coast Center Compliance Officer in accordance with Center policy and the corporate Compliance Plan
1. If it is inappropriate to discuss the issue with an immediate supervisor, the employee may raise the issue directly with the Gulf Coast Center Compliance Officer or appropriate Executive Management staff.
2. If necessary, the issue may be brought to the attention of the Gulf Coast Center Executive Director.
3. Reporting of violations will remain confidential to the extent possible unless otherwise obliged by professional code of conduct, state or federal law. Employees, contract providers and volunteers may, however, be required to substantiate any allegations of wrongdoing.
4. No employee, contract provider or volunteer will be punished or subjected to reprisal because he/she, in good faith, reports a violation of this Business Code of Conduct. Center policy regarding retaliation will be adhered to in all such instances.
5. Employee who deliberately make false accusations will be subject to disciplinary action up to and including termination.

XV. Risk Reporting

A. Risk Identification/Incident Reports (RIR) will be completed and submitted on all unusual occurrences/incidents. An occurrence is defined as an unusual event which transpires in or on the premises of the Center. The event is considered unusual if the result was unexpected, unintended, undesirable, and/or departs from any other Center policy and procedure and/or puts the Center in a position of liability or risk.
B. RIRs will be completed and submitted to the Client Rights Officer within:

    1. Twenty-four (24) hours if the incident involves abuse/neglect/ exploitation or some other rights violation, death of a consumer/client, or employee injury (workman’s comp).
    2. Forty-eight (48) hours for all other incidents except those listed in XV.B.1 immediately above.

C. A RIR will be completed by any person involved in or witnessing an incident or unusual
occurrence. This incident or occurrence is to be immediately reported to the supervisor or manager of the person(s) completing the RIR.

XVI Conclusion.

It is the responsibility of each employee, contract provider and volunteer to maintain the highest standards of business ethics. This includes taking positive action to prevent or correct any improper or inappropriate acts. The Gulf Coast Center Board of Trustees and Management are committed to providing avenues through which ethical issues may be raised, reviewed and resolved openly and honestly.

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