Code of Conduct

Dear Colleagues:

We have built a world-wide reputation at Cleveland Clinic of

providing outstanding clinical care enhanced by innovative
research and education. Because of caregivers who live our
values, we have earned the confidence of our patients and the
respect of our communities.

The name Cleveland Clinic stands for honesty and integrity at the
highest level. Our Cleveland Clinic Code of Conduct ensures we
continue to deliver on our promise to always do the right thing.

The Cleveland Clinic Code of Conduct is part of our overall

program of Corporate Compliance. It states the ethical principles
that rule our business and determine our actions in the
workplace. Medical and business decisions can be complex.
The Code of Conduct guides us to make the right choices.

All Cleveland Clinic trustees, caregivers, volunteers and service providers are required to observe
this Code of Conduct, abide by our legal and regulatory compliance policies, and conduct their
activities in an ethical manner.

We are all accountable for staying true to our values and our professional code of conduct.
We must work together to ensure our workplace environment is one that supports transparency
and always doing the right thing for our patients and one another.

If you have any questions about the Code of Conduct, or ethical concerns regarding any
situation arising at Cleveland Clinic, please contact your supervisor, the Department of Human
Resources, the Office of Corporate Compliance, or the Law Department. If you wish to remain
anonymous, you may call the confidential Reporting Line at 1.800.826.9294.

Thank you for helping Cleveland Clinic become the best place for healthcare delivery and the
best place to work in healthcare.

Sincerely,

Tomislav Mihaljevic, MD
Chief Executive Officer and President, Cleveland Clinic

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Code of Conduct

Purpose
Cleveland Clinic is committed to the highest standards of business ethics by acting with honesty and transparency in the
provision of health care services as well as in the management of its business affairs. The Code of Conduct, which has been
adopted by the organization, supplements the mission, vision and values of Cleveland Clinic and is an integral part of our
Corporate Compliance Program. Policies and procedures that support the Code of Conduct can be accessed on the intranet
or obtained from a supervisor in hard copy form.

Our Code of Conduct provides guidance to all in carrying out daily activities within appropriate ethical and legal standards.
The Code of Conduct provides standards of conduct to protect and promote integrity and to enhance Cleveland Clinic’s ability
to achieve its mission and compliance goals. The Code of Conduct is not intended to cover all situations and does not address
ethics related to medical care.

Who must abide by the Code of Conduct?

The Code of Conduct applies to the operations of Cleveland Clinic, at all Cleveland Clinic locations and regional hospitals,
and other entities within the Cleveland Clinic enterprise, the Cleveland Clinic Employee Health Plan, and to all individuals
and entities who provide services through or for Cleveland Clinic. This includes caregivers, clinical practitioners, volunteers,
contractors, vendors, board members and officers and others conducting business for, or on behalf of the Cleveland Clinic.
Because the Code of Conduct is integral to our values of integrity, Cleveland Clinic will impose disciplinary action or other
appropriate measures against those who fail to adhere to its principles.

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1. Integrity in 2. Integrity in Billing and
Patient Care Financial Practices
Patient Rights Accurate Books and Accounts
Cleveland Clinic continuously strives toward a culture of Cleveland Clinic payments and other transactions are to
patient safety and delivering world-class care to all of our be properly authorized by management, and are to be
patients. Caregivers are expected to honor the rights of accurately and completely recorded in accordance with
patients and to treat patients with dignity and respect, generally accepted accounting principles and established
while promoting a safe care environment. corporate policies. This serves as a basis for managing the
business and is important to meeting obligations to patients,
Patient confidentiality must be respected at all times.
suppliers and others. Cleveland Clinic’s high standard of
Patient information, including photos, must not be posted
accuracy and documentation is necessary for tax and
to a website, social media page or public forum without
financial reporting requirements.
appropriate authorization from the patient. Caregivers must
protect patient information at all times by knowing and The duty to report accurate and truthful information also
following the requirements of Cleveland Clinic’s privacy applies to our internal dealings. All work-time and expense
and security policies. records are to be reported accurately and honestly.

Emergency Treatment Billing

Cleveland Clinic will provide a medical screening examination Cleveland Clinic is committed to prompt, complete and
and, if appropriate, stabilizing treatment to all patients who accurate billing that complies with all applicable laws,
come to a Cleveland Clinic dedicated emergency department rules and policies. Caregivers who handle patient charges,
for emergency treatment, regardless of their ability to pay. claims and records are to accurately document and report
Cleveland Clinic will only transfer patients with emergency all services and supplies that are billed. Cleveland Clinic
medical conditions to another facility, in compliance with prohibits its caregivers or agents from knowingly presenting,
state and federal requirements and Cleveland Clinic policies. or causing to be presented, claims for payment or approval,
which are false, fictitious or fraudulent. When an overpayment
Research is identified, Cleveland Clinic will promptly return the amount
received in excess of the amount due and payable under any
Cleveland Clinic is committed to following ethical standards
regulatory requirements.
in full compliance with Federal and State laws and regulations
in any research, investigations and clinical trials conducted.
Cleveland Clinic is committed to integrity in disseminating
appropriate, valid scientific results in accordance with
applicable regulations and guidelines. It is Cleveland Clinic’s
priority to protect the rights of it subjects. As in all financial
accounting and record keeping, Cleveland Clinic’s policy is to
submit accurate and complete costs related to research grants.

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3. Integrity in the Appropriate Use of Resources
Theft, carelessness and waste have a direct impact on the
Work Place organization’s success. Those employed or performing duties
for the Cleveland Clinic have a duty to preserve and protect
Confidential Information the assets of the organization and to ensure their efficient use.
Caregivers, as well as with those who enter into business or Cleveland Clinic computers, systems and computer accounts
professional relationships with the Cleveland Clinic, are obligated are intended for business use only. All information transmitted
to maintain the confidentiality of patients, personnel and other or stored in its computers and systems, including email and
proprietary information. Sharing of confidential information voicemail messages, is considered business information of
with other caregivers or others outside the organization is Cleveland Clinic even if considered personal by a caregiver.
strictly forbidden, unless the person requesting the information Cleveland Clinic may use or review such information as it
has a legitimate reason to receive it for Cleveland Clinic deems appropriate.
business-related purposes and the information is shared in
an appropriate manner as to best protect the information. Travel and Entertainment
Confidential information includes protected health information, Travel and entertainment expenses of a caregiver must be
which may be accessed, used or disclosed only in accordance consistent with his/her job responsibilities and the needs and
with Cleveland Clinic privacy and security policies. resources of Cleveland Clinic. Caregivers are encouraged to
participate in and attend educational workshops, seminars
Intellectual Property and training sessions. Caregivers are expected to be good
Cleveland Clinic is committed to adhering to all applicable stewards of Cleveland Clinic resources when participating in
intellectual property laws. Additionally, Cleveland Clinic approved business travel or when seeking reimbursement for
will respect the intellectual property and copyright laws approved business expenses.
regarding books, trade journals, magazines and other
applicable resources. All software used in connection with Professional Conduct
Cleveland Clinic business must be properly licensed, and Intimidating and disrespectful behaviors disrupt the culture
used in accordance with that license. of safety and prevent collaboration, communication, and
teamwork, which are required for safe and highly reliable
Outside Activities and Employment patient care. Cleveland Clinic also has codes of conduct that
Cleveland Clinic caregivers and other service providers address specific health care professional responsibility to
owe a duty of complete loyalty to the Cleveland Clinic and patients and each other. Health care professionals must also
should refrain from directly or indirectly performing duties, follow the ethical standards dictated by their respective
incurring obligations, or engaging in business or professional professional organizations.
relationships where there is, or would appear to be a
conflict of interest. No outside activity may interfere with Drug Free Work Place
job performance. Caregivers, contractors or vendors may not be under the
influence of alcohol or illegal drugs on company property or
Family and Work during work time. Caregivers are required to report any unsafe
Employment of an immediate relative (including a situations to their manager or the Human Resources department.
spouse, parent, stepparent, child, stepchild, sister, brother,
son-in-law, daughter-in-law, sister-in-law, brother-in-law, Prohibition on Discrimination and Harassment
mother-in-law, father-in-law) is not permitted where a Cleveland Clinic is committed to providing a work
caregiver has a direct or indirect administrative, supervisory environment in which all individuals are treated with respect
or decision-making authority over the related person. and dignity. It is the policy of Cleveland Clinic to ensure that
the work environment is free from discrimination or harassment
on the basis of race, color, religion, gender, sexual orientation,
gender identity, pregnancy, marital status, age, national origin,
disability, military status, citizenship, genetic information, or
any other characteristic protected by federal, state, or local
law. Cleveland Clinic prohibits any such discrimination,
harassment, and/or retaliation.

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Gift Giving and Receiving 4. Legal and Regulatory
Cleveland Clinic strives to preserve and protect its reputation
of integrity at all times. Accepting gifts, entertainment or meals Compliance
from outside sources may create an appearance of impropriety All activity by or on behalf of Cleveland Clinic is
and may violate Cleveland Clinic policies. Caregivers are always to comply with all applicable federal, state and local
prohibited from soliciting tips, personal gratuities or gifts from laws and regulations.
any source.
Screening of Excluded Individuals
Caregivers are generally prohibited from offering gifts or
discounts to patients or physicians except in limited Cleveland Clinic will not knowingly employ or contract with
circumstances and with approval by senior management. individuals or entities that have been listed as debarred,
excluded or otherwise ineligible for participation in federal
Caregivers should consult with their supervisor or the Law health care programs. As a condition of employment,
Department for additional guidance. caregivers are required to notify human resources immediately
if they are currently, or to the best of their knowledge, will
Political Activity be in the future, listed by the Federal Department of Health
Cleveland Clinic does not participate or intervene in any and Human Services Office of Inspector General, the General
political campaign on behalf of, or in opposition to, any Services Administration or the applicable state Medicaid
candidate for political office. While Cleveland Clinic supports Exclusion and Suspension List as a person who is excluded
caregiver participation in the political process, caregivers are from participation in Federal or State health care programs.
not permitted to use their position in the organization to try
to influence the personal decision of others to contribute, or Adherence to Health and Safety Laws
to otherwise support political parties or candidates, except Cleveland Clinic caregivers and other health care providers
as lawfully permitted through political action committees. are expected to comply with laws designed to improve
Cleveland Clinic may choose to support specific issues with workplace safety, such as properly controlling and monitoring
the approval of the Law Department. dangerous materials and maintaining safe equipment.

Marketing and Advertising Environmental Protection

Marketing and advertising activities may be utilized for Caregivers are to dispose of all waste and other materials
the following purposes: to educate the public, to provide and store all chemicals and substances in accordance with
information to the community, to increase awareness of our applicable laws and regulations. It is important to file all
services and to recruit caregivers. Marketing materials and necessary environmental reports accurately and promptly and
media announcements are to be presented in a truthful, fully to cooperate fully with all government authorities in the event
informative and non-deceptive manner. of an environmental incident.

Media Relations Fraud, Waste and Abuse

All requests from news reporters, the general public or Cleveland Clinic policies and various federal and state laws
other external parties for information should be referred to prohibit fraudulent claims activity. The Federal False Claims
the Corporate Communications Media Relations Office. Act and state fraud and abuse prevention laws prohibit
All media requests must be coordinated by a Corporate conduct such as knowingly submitting a false or fraudulent
Communications representative. Caregivers should never claim, or using or making a false statement to get a false
release information to journalists or to the public without or fraudulent claim paid. Other laws governing Medicaid
permission of Corporate Communications. program integrity also look for ways to reduce fraud and
abuse. Cleveland Clinic and its caregivers and other service
providers can be prosecuted for filing inaccurate claims for
reimbursement, and can be subject to civil fines, criminal
penalties or both.

Performing routine audits or reviews and monitoring, along

with internal controls, help Cleveland Clinic prevent and
detect fraud, waste and abuse.

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Cleveland Clinic expects caregivers to report known or government official or other person or entity in connection
suspected activity of this type to the Corporate Compliance with Cleveland Clinic’s overseas transactions that does or
Office. Caregivers who lawfully report false claims or other might appear to secure an improper advantage in obtaining
fraudulent conduct or who otherwise assist in an investigation, or retaining business.
action or testimonies are protected from retaliation to the
furthest extent possible under both federal and state laws. Responding to Government Inquiries
Caregivers are advised to consult with the Law Department
Regulation of Controlled Substances and the Cleveland Clinic Chief Integrity Officer before
Many prescription drugs, controlled substances and other responding to any non-routine requests from or on behalf of
medical supplies are governed and monitored by specific local, state, or the federal government to make sure that
regulatory organizations and are to be administered by an contacts with government entities are handled properly.
authorized provider’s order only. Prescription and controlled Cleveland Clinic caregivers are to cooperate with any
medications and supplies are to be handled properly and only government inquiry and always be clear and truthful in
by authorized individuals to minimize risks to Cleveland response to those inquiries. When a caregiver is aware
Clinic patients. of an existing or potential government inquiry they are not
to alter or destroy records and should consult with the Law
Not-for-Profit Tax-Exempt Status Department if there are questions.
Cleveland Clinic is a tax-exempt entity because of its charitable
mission. Cleveland Clinic provides benefits that include
healthcare services, medical training, education, research and
community outreach activities. Cleveland Clinic must use its
5. Ethical Responsibility
resources in a manner that furthers the public good rather Abiding by the Code of Conduct is a condition of
than the private or personal interest of any individual or entity. employment for every Cleveland Clinic caregiver.
Caregivers are required to participate in all training
Antitrust activities required by Cleveland Clinic.

Cleveland Clinic engages in activities that are subject to state

Reporting Any Suspected or Actual Violations
and federal antitrust laws. Generally, these laws prohibit
competitors from entering into agreements to fix prices or to Caregivers and those affiliated with Cleveland Clinic have a
reduce price competition. Cleveland Clinic caregivers should responsibility to report any suspected or actual violation of the
not provide information about Cleveland Clinic business to a Code of Conduct or other policy irregularities to a supervisor,
competitor. In addition, caregivers are to refrain from the Corporate Compliance Office or the Law Department. For
engaging in unfair practices that might restrict competition. those who wish to remain anonymous, the report may be
submitted through one of the Cleveland Clinic Compliance
Anti-Kickback/Bribes Reporting Lines. However, it is important to understand that
the Compliance Reporting Line is intended to supplement,
Cleveland Clinic prohibits its caregivers and other service
not replace, other channels for communicating questions and
providers from offering, paying, asking for, or accepting any
concerns within the organization. It should be used when
money or other benefit in exchange for patient referrals,
other avenues of communication have not been effective.
purchases, leases or orders. All contracts and interactions
with other referral sources are to follow all applicable laws
Non-retaliation
and regulations.
There will be no negative consequences or retaliation for
Insider Trading good faith reporting of possible misconduct.

No caregiver of the Cleveland Clinic shall use non-public

Management Responsibilities
information acquired through employment at Cleveland Clinic
to trade in the securities of any company, or buy or sell any Managers must set an example and take action when
property or assets. compliance and ethical issues are raised. They are responsible
for ensuring that their caregivers know the content of the Code
Anti-Corruption Laws of Conduct. Managers are responsible for seeking help from
the Compliance Office for themselves and their caregivers
Cleveland Clinic caregivers will not offer, authorize or promise
when the right action is not clear and when questions arise.
to provide anything of value, directly or indirectly, to a foreign
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Resources and Contact Information
Violations or suspected violations of the law, Cleveland Clinic policy or this
Code should be reported. The Compliance Reporting Line is intended to
supplement, not replace, other channels for communicating questions and
concerns within the organization. It should be used when other avenues of
communication have not been effective or you are uncomfortable with disclosing
your identity when reporting a concern. The call will not be traced. Anonymity,
if requested, will be protected up to the limits of the law.

Cleveland Clinic Chief...................... 1.216.444.3692

Integrity Officer

Corporate Compliance Office............. 1.216.444.1709

Florida Compliance Office............. 1.772.419.2975
Akron Compliance Office.............. 1.330.344.5941

Law Department.............................. 1.216.448.0200

Florida Law Department................... 1.954.689.5700 Ext. 65700

System-wide Anonymous Reporting

Main Campus, Florida
and other facilities............................ 1.800.826.9294

Anonymous e-mail reporting option is also available from the Corporate

Compliance Intranet: http://portals.ccf.org/compliance/Report-a-Concern

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