Code Of Ethics—SCCDC Vendors/Suppliers

Skin Cancer and Cosmetic Dermatology Center, P.C. and its affiliates (collectively “SCCDC” or the “Practice”) are committed to acting with integrity, honesty and good faith in all areas. These principles define our culture and are the basis of every activity in which we are involved. This Code of Ethics (the “Code”) defines and reaffirms these high standards. Each vendor and service provider (collectively, the “Suppliers”) is expected to satisfy the ethical principles and procedures in this Code, and ensure that their employees, subcontractors and agents also comply. If there is an ambiguity in any provision of this Code, SCCDC reserves the right to interpret such provision at its sole discretion.  

Ethical Business Practices 

SCCDC is committed to conducting its business in accordance with the highest ethical standards and in compliance with all applicable laws, rules and regulations. Suppliers are expected to share its principles, uphold its standards and for each to develop policies and programs as appropriate to ensure that all workers understand and satisfy these standards. 

 A) Anti-Bribery & Anti-Corruption 

SCCDC does not tolerate bribery or corruption involving its suppliers, agents or other business partners. Suppliers are expected to fully comply with applicable laws, rules, regulations and governing standards prohibiting or otherwise proscribing in any form bribery and/or corruption.

Suppliers are prohibited from offering, providing, paying, authorizing, promising, soliciting or receiving anything of value, directly or indirectly, for the purpose of obtaining or retaining business or any improper business advantage for or from SCCDC. This prohibition extends not only to SCCDC personnel, representatives, and agents, but also to public officials (including candidates for office, employees or officers of state-owned/controlled enterprises), employees or officers of counterparties, patients/customers or suppliers (as well as their relatives, friends, agents and associates). Suppliers are also prohibited from making facilitation payments, which are payments to public officials to expedite or secure performance of a routine, non-discretionary governmental action. Suppliers and other third parties acting on behalf of SCCDC (including intermediaries/finders, agents and business partners) are expected to maintain appropriate policies and procedures and act at all times in a manner consistent with this Code.

 “Anything of value” includes improper payments, such as cash bribes or kickbacks, and may also include other direct or indirect inducements, benefits, fees, commissions and advantages, including inappropriate gifts, meals, travel, entertainment, charitable and political contributions, and offers of employment or internships. "Anything of value" can also include payments disguised as legitimate fair value payments for goods or services not appropriately delivered. Nothing herein however shall prohibit Suppliers from paying fair value for services or goods actually and appropriately provided.

 B)  Gifts, Travel & Entertainment 

Suppliers must not provide excessive or otherwise inappropriate gifts, fees, favors, other compensation, including travel and entertainment, that are intended to influence, or may appear to influence, a business decision. The offering of gifts, travel and entertainment may create an inappropriate obligation or expectation or appearance of an improper exchange. It can also raise issues even if no benefit was ultimately provided.

 The receipt of gifts, loans or special favors from others (including actual or potential competitors or patients) having actual or potential business or other dealings with SCCDC can create the appearance of impropriety. Accordingly, Supplier employees may not solicit, directly or indirectly, gifts or special favors from such parties for themselves or others. Supplier employees must promptly report the offer or receipt of any gifts or other favors inconsistent with these policies to the SCCDC Compliance Officer.

 C)  Other Conflicts of Interest

Suppliers must avoid improprieties and conflicts of interest or the appearance of either. A conflict of interest may exist when a supplier is involved in an activity that affects – or could appear to affect – objectivity. 

 D)  Privacy and Data Protection 

Suppliers are required to protect the privacy and security of confidential information, including the use and disclosure of Protected Health Information (PHI). Suppliers may be required to sign a Business Associate Agreement (BAA) if Supplier assists in performing certain functions or activities that involve the use or disclosure of PHI.

Suppliers must also adopt and maintain processes to provide reasonable protections for personal, proprietary and sensitive information as the unauthorized use or disclosure of such information may have personal, legal, reputational and financial consequences for the individuals whose personal information may be implicated, and for SCCDC.

Suppliers may be required to sign other agreements where Supplier accesses, stores and/or interacts with SCCDC systems or confidential or sensitive information.

 E)  Grievance Mechanism

Suppliers are required to have a process through which their workers can raise workplace concerns without fear of retaliation (including through the use of anonymous reporting modes). This grievance mechanism should be easily accessible and understandable and provide for the protection of whistleblowers. 

 F)  Additional Requirements (as applicable) 

Where Federal law requires that SCCDC establish for and disseminate to Supplier employees or workers written policies requiring compliance with federal and state laws relating to fraud and abuse, whistleblower protections and/or other governmental program requirements, SCCDC will notify Supplier and direct that they follow this link: www._______________ or require that they contact the SCCDC Compliance Officer.