BUSINESS CONDUCT, COMPLIANCE AND ETHICS PROGRAM

Novation’s commitment to compliance by all employees is an essential component of our core business practices and is critical to the success of our mission. To this end, Novation has a comprehensive Business Conduct, Compliance and Ethics Program, including ongoing monitoring and employee certifications regarding compliance with Novation’s business practices.

• Letter from Novation President Jody Hatcher
• General Standards
• Governance & Oversight
• Conflicts of Interest
• Employee Relations — Respecting the Rights of Employees
• Corporate Social Responsibility
• Business and Governmental Relations
• Supplier Expectations
• Quality Assurance/Regulatory Affairs
• Reporting Violations
• Determining When Your Ethics Are Being Challenged and What to Do

The Novation Business Conduct, Compliance and Ethics Program reflects the principles outlined in these Standards, the Code of Conduct adopted by the Health Industry Group Purchasing Association (HIGPA) and the Healthcare Group Purchasing Industry Initiative¹, along with other related industry and governmental compliance guidance and applicable law.

The Business Conduct, Compliance and Ethics Program includes the following key elements:

• Standards of Business Conduct (view printable version)
• Policies and Procedures that Supplement the Standards of Business Conduct
• Confidential Procedure for Asking Questions and Reporting Compliance Concerns
• Compliance Hotline and Web site
• Ongoing Auditing and Monitoring System
• Regular Compliance Training

Novation’s Compliance Department, led by the Ethics and Compliance Officer, works with senior management to ensure compliance with the Business Conduct, Compliance and Ethics Program. Additional oversight is provided by the Compliance and Audit Committee of the Novation Board of Directors.

¹ HIGPA is a trade association of purchasing organizations that provides advocacy, education, ethical guidance and other services to member purchasing organizations. HGPII is a health care group purchasing organization initiative dedicated to the adoption and implementation of a core set of principles of business ethics and conduct. Novation was a founding member of, and continues to actively participate in, both HIGPA and HGPII.