COMPLIANCE

 

Mednax has a robust ethics and compliance program founded on the Seven Elements of an Effective Compliance Program. It is the company’s responsibility and commitment to foster a culture that facilitates and encourages ethical conduct and compliance with all applicable laws, rules and regulations. The compliance program provides Mednax associates with a support system that promotes adherence to required ethical and legal standards. This includes the establishment of a compliance department and appointment of a chief compliance officer, supported by the compliance committee, which administers the program. The committee provides compliance training and education; manages procedures to prevent, detect and correct improper business practices and conduct; establishes policies and procedures that will guide and assist associates in meeting their compliance and ethical obligations; integrates compliance into the company’s daily operations across all levels of the company; and fosters a corporate culture where associates can report compliance concerns without fear of retaliation and with an expectation that such issues will be resolved in a timely manner.

PATIENT PRIVACY

 

Mednax maintains a patient privacy program that protects each patient’s right to privacy of his or her protected health information, or PHI, as required by HIPAA and applicable federal regulations and interpretive guidelines. The patient privacy program fosters a culture of privacy compliance that demonstrates the company’s commitment to appropriately safeguard the privacy of an individual’s protected health information. The patient privacy program includes:

  • Creation and implementation of company privacy policies and procedures.
  • Education of all associates regarding the HIPAA Privacy Rule, as amended, the HITECH Act and Company privacy policies and procedures.
  • Implementation of appropriate administrative, technical and physical safeguards.
  • Execution of written agreements with business associates.
  • Implementation of a process to routinely monitor compliance with the company’s privacy policies and procedures, HIPAA standards and the HITECH Act. 

The privacy program is managed and overseen by Mednax’s privacy officer in the compliance department with guidance and support from the compliance committee. Privacy requirements and expectations are documented in the company’s HIPAA policy repository available to all associates on the Mednax policy site. Associates are trained upon hire and annually on the appropriate collection, usage, retention, disclosure and destruction of PHI. Administrative, technical and physical safeguards are implemented to protect health information from any intentional or unintentional use or disclosure that violates privacy policies, the HIPAA Privacy Rule or the HITECH Act. Business Associate Agreements are executed for all vendors that handle, use, distribute or access patient PHI on behalf of the company. The compliance department publishes the compliance helpline and privacy officer email address as a method to report possible HIPAA violations. The privacy officer, in conjunction with the legal department and the information technology department, investigates all suspected or potential privacy incidents. Root-cause analysis is performed on all substantiated privacy incidents. Remediation efforts are employed to mitigate further risk of compromise and prevent future incidents. The company reports all significant incidents to the compliance committee and the board of directors.

INFORMATION SECURITY

 

The integrity and security of Mednax information systems and data are critical to its business. Electronic clinical information systems play a significant role in the company’s operations.

Mednax takes extensive steps to protect the security of these systems and the data contained within them. It continually tests the suitability of its security and disaster-recovery measures and has implemented administrative, technical and physical safeguards within its systems and employed processes to help prevent unauthorized access.

The company follows the National Institute of Standards Technology cybersecurity framework, which provides best practices to prevent, detect and respond to cyberattacks.

As part of its modern information security program, Mednax continually monitors, evaluates and tests the tactics, tools, techniques and processes used by threat actors to adequately prepare and provide a trusted environment for its patients, clinicians, associates and other stakeholders.

The external risk-assessment process includes:

  • Information-security reviews.
  • Penetration tests.
  • Continuous internet perimeter vulnerability scanning and evaluation.
  • Industry and expert security collaboration in current and emerging threats.
  • Incident-response exercises.

The company practices resilience on a routine basis through:

  • An annual incident-response-plan exercise.
  • Disaster-recovery exercises.
  • Corporate business-continuity exercises.
  • Penetration tests and risk assessments performed by external parties.
  • Continual security-awareness training for all associates and board members, including quarterly email-phishing exercises.
  • Continual advancements of tools and techniques that focus on vulnerability threat intelligence, discovery and patching to protect and defend the environment.
  • ·Regular reports to the board of directors on the company’s information security, which occur at least annually.

HUMAN RIGHTS

 

Mednax’s mission, vision and values statements define the company and how it operates. Its values ensure that the company builds trust, empowers all, embraces change, demonstrates respect, is accountable and celebrates success. These values, along with its mission and vision, are the foundation for the company’s human rights commitments, as expressed in its human rights policy. 

The policy is fundamental to the company’s commitment to operate with empowerment, respect and accountability in everything it does. It is supported by Mednax’s code of conduct and supplier code of conduct. The company operates with respect to internationally recognized human rights, including those affirmed in the United Nations’ Universal Declaration of Human Rights.

While Mednax recognizes and acknowledges the fundamental rights of workers and organized labor to freely associate and collectively bargain in compliance with federal and state laws, it believes there is great value in the one-on-one relationship between a leader and a team member and that Mednax’s culture of openness and inclusion renders the need for collective bargaining unnecessary.

Mednax conducts regular training and awareness-raising activities and will expand these to provide associates with guidance on its human rights commitments and provide the tools they need to uphold the commitments.

Statement on Human Rights

DIVERSITY AND INCLUSION

 

Diverse perspectives encourage different solutions, and inclusion inspires ideas. Fully embracing diversity helps avoid or minimize the very detrimental effects of bias and discrimination. Mednax welcomes new ways of thinking and works diligently to ensure an environment where everyone is welcome and treated as equals and where everyone’s voice can be heard. Diversity reflects all ways the company is unique and distinctive, and it combines those attributes with its many similarities to form a cohesive workforce. Inclusion fosters an environment in which coworkers can proudly come to work every day and have the opportunity to contribute their best work. Mednax believes that when it embraces differences and intentionally includes all stakeholders — associates, customers, suppliers, investors and the communities it serves — it provides the utmost opportunity to win together, drive superior results and maximize shareholder value.

Policy on Diversity Equity Inclusion

HUMAN TRAFFICKING

 

Mednax’s forced-labor, human-trafficking and modern-slavery policy prohibits the use of all forms of forced labor, including prison labor, indentured labor, bonded labor, military labor, modern forms of slavery and any form of human trafficking.

The company takes seriously its responsibility to prevent and prohibit the practice of human trafficking. It has adopted a policy against human trafficking, which applies to all Mednax associates, agents, contractors, suppliers and subcontractors.

The policy prohibits associates from engaging in any behavior related to the trafficking of persons. Prohibited behavior includes, but is not limited to:

  • Engaging in trafficking in persons, including sex trafficking and any recruiting or obtaining of workers through force, fraud, coercion and involuntary servitude or slavery.
  • Procuring commercial sex acts.
  • Using forced labor in company business or the performance of a contract.
  • Withholding or destroying an associate’s identification or immigration documents.
  • Using fraudulent tactics in recruiting workers or using recruiters who use dishonest tactics.

Associates who become aware of activity that may involve human trafficking must notify a supervisor or human resources personnel of the action immediately. A person who reports potential violations under this policy in good faith will not face retaliation in any manner.

If Mednax becomes aware of possible activities involving human trafficking by an associate, subcontractor or associate of a subcontractor, it will investigate and take appropriate corrective action.

Policy on Forced labor Human Trafficking Modern Slavery

EQUAL OPPORTUNITY AND WORKFORCE/LABOR RIGHTS

 

Mednax subscribes to the equal opportunity requirements of federal laws, regulations, and executive orders, as well as the laws of the states and municipalities in which it conducts business. The company is committed to hiring and developing the most qualified individuals from the available workforce in the communities it serves. Its equal opportunity and workforce/labor rights ensure equal opportunity to all associates and applicants in all employment matters, including but not limited to, recruitment, hiring, placement, compensation, training, promotion and separation. In these and all activities, the company does not discriminate against any qualified individual because of sex, age, race, color, religion, creed, national origin, ancestry, familial status, marital status, sexual orientation, gender identity, disability, handicap, genetic information, liability for service in the United States Armed Forces, veteran status or any other legally protected characteristic.

Policy on Equal Employment Opportunity

SEXUAL HARASSMENT

 

All associates are entitled to work in an environment completely free of implicit or explicit physical or verbal harassment of a sexual nature. No Mednax associate shall be subject to sexual harassment from another associate or any individual doing business with the company. Sexual harassment includes same-sex harassment.

Policy on Equal Employment Opportunity

OTHER UNLAWFUL HARASSMENT

 

All associates are entitled to work in an environment completely free of implicit or explicit physical or verbal harassment based on age, race, color, religion, creed, national origin, sexual orientation, gender identity, disability, handicap or any other protected characteristic. No Mednax associate shall be subject to any unlawful harassment from another associate or any individual doing business with the company.

Policy on Equal Employment Opportunity

AGE DISCRIMINATION

 

Mednax subscribes to the tenets of the Age Discrimination in Employment Act of 1967 (ADEA) and the Older Workers Benefit Protection Act (OWBPA). The company does not discriminate against any associate or applicant, including those 40 years of age or older. Age is not considered in recruiting, hiring, training, promoting, compensating, providing benefits, taking corrective action or separating an associate or any other term or condition of employment.

Policy on Equal Employment Opportunity

AMERICANS WITH DISABILITIES

 

Mednax complies with the Americans with Disabilities Act of 1990 (ADA) and the ADA Amendments Act of 2008 (ADAAA) in all matters of employment, including recruiting, hiring, training, promoting, compensating, providing benefits, taking corrective action or separating an associate, or any other term or condition of employment.

Policy on Equal Employment Opportunity

STANDARDS OF CONDUCT

 

To provide the best possible work environment, Mednax expects associates to follow the rules of conduct that will protect the interests and safety of all associates and the company. These include, but are not limited to:

  • Theft or inappropriate removal or possession of property.
  • Falsification of timekeeping records.
  • Working under the influence of alcohol or illegal drugs.
  • Possession, distribution, sale, transfer or use of alcohol or illegal drugs in the workplace while on duty or when operating employer-owned equipment.
  • Fighting or threatening violence in the workplace.
  • Boisterous or disruptive activity in the workplace.
  • Negligence or improper conduct leading to damage of employer-owned, co-employee-owned or patient-owned property.
  • Insubordination or other disrespectful conduct.
  • Violation of safety or health rules.
  • Smoking in prohibited areas.
  • Sexual or other unlawful harassment.
  • Possession of dangerous or unauthorized materials, such as explosives or firearms, in the workplace.
  • Excessive absenteeism or any absence without notice.
  • Unauthorized absence from workstation during the workday.
  • Unauthorized use of telephones, mail systems or other employer-owned equipment.
  • Unauthorized disclosure of confidential business information or trade secrets.
  • Unauthorized disclosure of associate information.
  • Violation of patient privacy/HIPAA policy.
  • Violation of company policies.
  • Unsatisfactory performance or conduct.

Policy on Equal Employment Opportunity

VIOLENCE IN THE WORKPLACE

 

Mednax provides a safe workplace for all associates. To ensure a safe workplace and reduce the risk of violence, all associates are required to review and understand all workplace-violence provisions in all workplace policies.

The company does not tolerate any workplace violence committed by or against an associate. Associates are prohibited from making threats or engaging in violent activities. Threats, threatening conduct or any acts of aggression or violence in the workplace will not be tolerated. Any associate who is determined to have committed such acts will be subject to corrective action, up to and including termination. Non-employed persons engaged in violent acts on company premises will be reported to the proper authorities and fully prosecuted.

Mednax takes extensive risk-reduction measures to ensure a violence-free environment for its associates and the company, including:

  • Hiring: Mednax’s human resources department conducts background investigations to review candidates’ backgrounds and reduce the risk of hiring individuals with a history of violent behavior.
  • Safety: The company conducts annual inspections of the premises to evaluate and determine workplace violence or hazards vulnerability. All necessary corrective actions are taken to mitigate risks.
  • Individual situations: The company does not expect associates to be skilled at identifying potentially dangerous persons. However, all associates are expected to exercise sound judgment and inform the human resources department if any associate exhibits behavior that could be a sign of a potentially dangerous situation. 

Policy on Equal Employment Opportunity

HEALTH AND SAFETY

 

All Mednax facilities comply with all government regulations and rules related to workplace health and safety. The company policies, procedures and practices promote workplace health and safety. These tools help protect colleagues from potential workplace hazards. Associates must become familiar with and understand how these policies apply to their specific job responsibilities and seek advice from their supervisor whenever they have a question or concern. Associates must immediately advise their supervisors of any serious workplace injuries or situations that may cause harm, so timely corrective action may be taken.

Policy on Health and Safety

WORKERS’ COMPENSATION

 

To provide for payment of medical expenses and partial salary continuation in the event of a work-related accident or illness, Mednax associates are covered by workers’ compensation insurance. Payable benefits and the duration of payment depend on the nature of the injury or illness. In general, however, all medical expenses incurred in connection with a work-related injury or illness are paid in full, and applicable partial salary payments will be provided.

To ensure that the company can assist in obtaining appropriate medical treatment, associates must immediately report work-related injuries or illnesses to their supervisor or the benefits department. Failure to comply may result in the failure to file the appropriate workers’ compensation report in accordance with the law, which may jeopardize the right to benefits in connection with the injury or illness.

Policy on Workers Compensation

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