Dear HealthTrust Colleague,

We have established this Code of Conduct as the foundation upon which we base our everyday
conduct at HealthTrust. Following this Code enables us to best fulfil our mission:
HealthTrust is committed to strengthening provider performance and clinical
excellence through an aligned membership model and the delivery of total cost
management solutions, including a contract and service portfolio unparalleled in
quality, scope and value.
This Code of Conduct provides guidance to ensure our work is done in an ethical and legal manner.
It emphasizes the shared common values and culture that guide our actions. It also contains
resources to help resolve questions about appropriate conduct in the workplace. Please review
it thoroughly. Your adherence to its spirit, as well as its specific provisions, is absolutely critical to
fulfilling our mission and maintaining a healthy work environment.
If you have questions about this Code, or if you encounter any situation that you believe may
violate a provision of this Code, you should immediately consult your supervisor; another member
of HealthTrust management; HealthTrust’s assistant vice president – ethics and compliance officer;
the local ethics and compliance officer at your facility in the U.S., HealthTrust Europe in the U.K. or
our Shanghai, China office; or the HealthTrust Ethics Line phone numbers that you will find at the
back of this Code. You have my personal assurance that there will be no retribution against you for
asking questions or raising concerns about this Code, or for reporting possible improper conduct.
No Code of Conduct can substitute for each person’s own internal sense of fairness, honesty
and integrity. Thus, if you encounter a situation or are considering a course of action that does not
feel right, please discuss it with any of the resources mentioned above.
Our mutual efforts to support the values and principles of this Code of Conduct will enable
HealthTrust to provide industry-leading total cost management solutions to all of our members
and clients.


Edward Jones
President and Chief Executive Office


This Code of Conduct is effective March 1, 2015.

Some defined terms:
• “Client” means a customer of HealthTrust that receives fee-based consulting services from
HealthTrust and, in some cases, custom contracting or other services.
• “Equity partners” means the limited partners of HealthTrust Purchasing Group, L.P.
• “General partner” means HPG Enterprises, LLC, the general partner of HealthTrust.
• “HealthTrust,” the “organization” or the “Company” means HealthTrust Purchasing Group, L.P.
and/or its affiliates, as applicable, including HealthTrust Europe LLP, and the Representative
Office of HealthTrust in Shanghai, China.
• “HealthTrust advisory board” or “advisory board” means the HealthTrust equity advisory
committee, and any other advisory board or committee established by HealthTrust, comprised
of member representatives, and whose purpose is to provide input and recommendations
related to supplier contracting and other HealthTrust matters, including HealthTrust Europe’s
evaluation panels.
• “HealthTrust colleague” or “colleague” means an individual who works full- or part-time for
HealthTrust, or an advisory board member.
• “HealthTrust Equity Advisory Committee” means the advisory committee made up of
representatives of the partners of HealthTrust Purchasing Group, L.P.
• “Member” means an organization that has signed a Participation Agreement with HealthTrust
(or, for HealthTrust Europe, an Order Form or other participation agreement) under which it
participates in HealthTrust’s group purchasing program.
• “Partners” means the equity partners and the general partner of HealthTrust Purchasing
Group, L.P.


HealthTrust is committed to strengthening provider performance and clinical excellence through an
aligned membership and the delivery of total cost management solutions, including the industry’s
benchmark portfolio in quality, scope and price.

Our Vision

To become the total cost management solutions company of choice for healthcare providers and
market leaders.

Our Values

As we pursue our mission and vision we are guided by these values:
• Client-centered – We serve and enable those who care for and improve human life in their
communities, including our members’ missions of social stewardship and workplace diversity.
“We serve a broader purpose.”
• Innovative – We pursue continuous improvement and foster creative solutions. “We are
thought leaders.”
• Service Excellence – We strive to exceed high standards and specific performance metrics in
all that we do. “We are focused on results.”
• Collaborative – We foster a work environment that engages and empowers employees to
achieve our goals. “We are adaptive and flexible.”
• Accountable – We honour our commitments and take personal responsibility for our actions.
“We support each other’s personal success.”


Our Code of Conduct provides guidance to all HealthTrust colleagues in carrying out our
daily activities within appropriate ethical and legal standards. These obligations apply to our
relationships with our members, clients, suppliers and one another. We act with absolute honesty,
integrity and fairness in the way we conduct our business and lead our lives.
The Code applies to all individuals who work full- or part-time for HealthTrust, including employees
and others who work for HealthTrust in the U.S. (directly or under a services agreement),
HealthTrust Europe LLP in the U.K. or the Shanghai office of HealthTrust in the People’s Republic
of China (P.R. China). It also applies to our independent contractors, and any non-employee
who serves as a member of the HealthTrust Equity Advisory Committee or any other HealthTrust
advisory board. We refer to all of these individuals as HealthTrust colleagues in this Code.
The Code is a critical component of our overall Ethics and Compliance Program. We have
developed the Code to help ensure that we meet our high ethical standards and comply with
applicable laws and regulations. These standards are mandatory and must be followed.
The Code is intended to be comprehensive and easily understood. In some instances, the Code
deals fully with the subject covered. In many cases, however, the subject requires additional
guidance for those directly involved with the particular area to have sufficient direction. To provide
additional guidance, we have developed a comprehensive set of policies and procedures that may
be accessed on our intranet in the U.S., U.K. and our Shanghai office. Some of these policies and
procedures may also be accessed on HealthTrust’s external website in the U.S. at HealthTrust
Ethics and Compliance, and in the U.K. at HealthTrust Europe Ethics and Compliance. These
policies are not a part of this Code of Conduct, but they expand upon or supplement many of the
principles articulated in this Code. These standards, like the Code, are mandatory and must be
As a global company, we are sensitive to local customs and requirements, but we must always
conduct ourselves in a way that is consistent with this Code. The Code is sometimes more
restrictive than applicable laws and regulations, and you are required to abide by the Code even
when it imposes requirements that go beyond legal obligations. The country in which you work has
additional laws that apply to you. Also, under some circumstances, you may be subject to the laws
of other countries in which HealthTrust operates even if you do not work in those countries. If you
are uncertain of the applicable legal requirements, you should bring the matter to the attention of
the HealthTrust Legal Department.


While all HealthTrust colleagues are obligated to follow this Code, we expect our leaders to set
the example. We expect everyone in the organization with supervisory responsibility to exercise
that responsibility in a manner that is kind, sensitive, thoughtful and respectful. We expect each
supervisor to create an environment where all team members are encouraged to propose ideas and
raise concerns.
We also expect that all supervisors will ensure that their team members 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 HealthTrust that promotes the highest standards of ethics
and compliance. This culture must encourage everyone in the organization to share concerns if they
arise. We must never sacrifice ethical and lawful behavior in the pursuit of business objectives.
In addition, all leaders should be aware that HealthTrust supports and utilizes various training
programs to help our supervisors develop and maintain excellent managerial skills. These tools
are coordinated by our Human Resources managers. The foundational principles of these tools
reflect the basic concepts of our Ethics and Compliance Program. The Ethics and Compliance
Program, together with our leadership training efforts, encourages what we refer to as “principled
leadership.” Such leadership assumes that those in our organization will lead by example, will
confront problems directly and candidly, will be inclusive in identifying individuals to participate
in the decision-making process, will give the maximum responsibility as appropriate to those who
work with them and will emphasize effective team-building. In addition to these fundamental
approaches to principled leadership, we expect those in our organization to understand and care
about their colleagues. HealthTrust’s work is accomplished each day, for the most part, in small
team settings. This encourages all leaders to strive to ensure that the talents of each member of
the organization are utilized to the maximum extent possible and that we give careful attention to
the professional development of everyone within HealthTrust.


We affirm the following commitments to HealthTrust stakeholders:
To our members: We are committed to strengthening provider performance and clinical excellence
through an aligned membership and the delivery of total cost management solutions, including the
industry’s benchmark portfolio in quality, scope and price.
We are equally committed to honoring the unique culture of our member organizations by being
familiar with their beliefs, charters and practices. We endeavor to exemplify each member’s mission
in our actions and to be viewed as an extension of the member’s organization.
To our HealthTrust colleagues: We are committed to a work environment where all colleagues are
treated with fairness, dignity and respect, and where they have an opportunity to grow, develop
professionally and work in a team environment in which all ideas are considered.
To the partners of HealthTrust: We are committed to fully performing our responsibilities to
manage HealthTrust in a manner consistent with the purpose of our partnership, our mission and
values and all applicable legal requirements.
To our suppliers: We are committed to fair competition among our contracted and potential
suppliers and to professional communication practices that will enhance our relationships with
them. We strongly encourage our suppliers to adopt the AdvaMed Code of Ethics or a comparable
code for their industry and comply with it in performing their obligations under our contracts.
To our regulators: We are committed to an environment in which compliance with rules,
regulations and sound business practices is woven into the corporate culture. We accept the
responsibility to aggressively self-govern and monitor adherence to the requirements of law and to
our Code of Conduct.


As a HealthTrust colleague, you need to be aware of the following efforts to assure our stakeholders
that we operate with unquestioned integrity:
• We have an Ethics and Compliance Program with a senior executive designated as our ethics and
compliance officer, referred to herein as the HealthTrust ECO. We also have local ECOs at HealthTrust
Europe in Birmingham, U.K., our representative office in Shanghai and our Schaumburg, Ill. office,
referred to herein as the Local ECOs.
• If a HealthTrust colleague in a decision-making role has a personal, financial or other private
interest in any contracted or prospective HealthTrust supplier, the matter must be fully disclosed to
HealthTrust and the colleague will be excluded from matters relating to the conflict in a way that
effectively mitigates the conflict.
• HealthTrust does not as of this writing have an ownership interest in any prospective or contracted
HealthTrust supplier. Such an interest could create an appearance of favoritism and lack of
independence in managing contract decisions for the benefit of our members and clients. HealthTrust
would consider obtaining such an interest only for reasons that benefit members and clients generally,
such as a need to create or maintain a source of supply for products or services where there is no
other source, or limited sources.
• HealthTrust does not invest in venture capital funds.
• HealthTrust does not invest in product research initiatives.
• HealthTrust does not have an ownership interest in Global Health Exchange (GHX), our contracted
e-commerce company (although an affiliate of HealthTrust’s general partner owns a small minority
• We believe maintaining business relationships with minority-owned and women-owned business
enterprises, and service-disabled veteran-owned small businesses is beneficial to our members and
• HealthTrust does not accept or contract for administrative fees from any supplier in excess of 3
percent, as allowed under the U.S. federal GPO Safe Harbor (42 U.S.C. Section 1320a-7b(b)).
• HealthTrust may receive a global sourcing fee from its members for products obtained through its
Global Sourcing program. These fees range from 0 percent to a maximum of 5 percent of the sourcing


HealthTrust manages its relationships with suppliers in a fair and objective manner that promotes
competitive procurement consistent with applicable laws and good business practices. Our
purchasing decisions are made based on the ability of the supplier to meet our members’ and
clients’ needs and not on personal relationships or investments. Our criteria include quality,
technical excellence, price, delivery, service and maintenance of adequate sources of supply.
We employ the highest ethical standards in business practices, source selection, negotiation,
determination of contract awards and the administration of all purchasing activities. HealthTrust’s
Business Relationship Statement, available on our external website, sets forth HealthTrust’s
expectations for the conduct of our suppliers in relation to HealthTrust and our members and
Organizations that compete unsuccessfully through HealthTrust or for whatever reason elect not to
compete through HealthTrust should respect the efforts of HealthTrust to maintain compliance with
the agreements that we have awarded.

HealthTrust participates in the Healthcare Group Purchasing Industry Initiative as a founding
member. This is an umbrella group of the major healthcare group purchasing organizations in the
U.S. and is intended to promote the highest standards of business conduct in group purchasing
organization activities.

New Technologies
We encourage those with new technologies or product innovations to be certain that HealthTrust
fully understands their capabilities and, in addition, we urge our advisory boards to bring new
technologies to our attention. We have a policy that sets out a process for this important flow
of information. See Policy HT.018 – Guidelines for the Introduction, Evaluation and Contract
Recommendation for New Technology.

Participation in HealthTrust Events
HealthTrust regularly presents and sponsors educational activities and conferences for the benefit
of its members and others. It may raise revenue for itself by offering exhibition booth space or
sponsorship opportunities at such events to suppliers that have a national contract available to
all HealthTrust members at the time of the event. All participating suppliers must be charged a
like amount for like opportunities (except that reduced prices may be offered at HealthTrust’s
discretion pursuant to its Supplier Diversity Program). No supplier can be required to participate
and its decision on whether to do so will have no impact on any contracting, contract renewal or
other HealthTrust business decision. If, in connection with such an event, a supplier offers a meal or
entertainment that is available only to HealthTrust colleagues, it is considered a business courtesy
and subject to the limitations and reporting requirements of Policy HT.006 – Business Courtesies
Received by HealthTrust Colleagues from Others. A meal or entertainment at a HealthTrust
event may not be offered by a supplier solely or primarily for a HealthTrust advisory board or its
members, to avoid providing special access to HealthTrust decision-makers at HealthTrust events.
Product samples that may be distributed by a supplier at such an event are not considered to be
gifts subject to our business courtesies policy. All such samples received by HealthTrust must be
used for product evaluation and documented per HealthTrust’s product evaluation process and
may not be taken for personal use. If a physician (or other potential source of patient referrals to
healthcare facilities of HealthTrust members) is participating in a HealthTrust event as a speaker,
panelist or advisory board member or providing other support, a written agreement is required
and other requirements of Policy HT.019 – Agreements with Professionals Who May Be Referral
Sources, must be met. See Policy HT.004 – HealthTrust Events for more guidance.

Participation by HealthTrust Colleagues in Educational, Training and Promotional
Events of Others
An educational, training or promotional event such as a conference or trade show presented
and sponsored by a supplier or an industry or professional association may be attended by a
HealthTrust employee only if HealthTrust pays all expenses for registration, meals, travel and
lodging related to the event. The business and educational components of the event must
predominate over all other activities taken together. Members of HealthTrust advisory boards
must also adhere to these restrictions if they are attending the event at HealthTrust’s request
and expense. Limited exceptions to these restrictions are set forth in Policy HT.007 – HealthTrust
Colleague Participation in Educational, Training and Promotional Events of Others, and include
the following: free or reduced registration expenses and modest meals or entertainment may be
accepted if part of the event agenda and available to all attendees. If a HealthTrust employee is
speaking at an event session or is on an advisory board of the sponsoring organization, payment
of customary expenses for his or her travel, lodging, meals and modest entertainment may be
accepted from the sponsor. However, no honorarium or speaker’s fee may be accepted by the
employee. If a supplier offers a meal or entertainment event to HealthTrust colleagues but not
to all attendees in connection with an event, it is considered a business courtesy and subject to
the limitations and reporting requirements of Policy HT.006 – Business Courtesies Received by
HealthTrust Colleagues from Others. If a supplier sponsors a function solely or primarily for an
advisory board as a group, the advisory board members may attend if the function does not occur
during the “quiet period” described in the Business Courtesies section of this Code. The board
lead should report the event as a business courtesy received. See also Policy HT.007 – HealthTrust
Colleague Participation in Educational, Training and Promotional Events of Others.

Physician-owned Suppliers
Federal and state laws in the U.S., and U.K. laws, govern the relationship between physicians and/
or any contracted supplier that is owned in whole or in part by a physician and hospitals to which
such physician may refer patients. The primary U.S. federal laws governing these arrangements are
the Anti-kickback Law and the Stark Law. It is important that those colleagues who interact with
physicians and/or physician-owned companies are aware of the legal requirements, which generally
require that there be no transactions with a physician or physician-owned company for the purpose
of generating referrals to any member or client healthcare facility.
HealthTrust will disclose to its members and clients any contracted suppliers that have physician
ownership and are not publicly held corporations. The HealthTrust contract award status for such a
supplier will not impose any requirement on a member or client to purchase under these contracts.

Charitable Activities
HealthTrust occasionally participates in charitable fundraising activities and we may provide
opportunities for our suppliers to do so as well, with advance written approval by the CEO. Any
such solicitations by HealthTrust to our contracted or prospective suppliers must be made in
writing and include a statement that the supplier’s decision on whether to participate will have no
impact on any contracting or other business decision that may be made by HealthTrust, and that
any funds the supplier may elect to contribute must be given directly to the charity rather than
indirectly through HealthTrust.

Accuracy, Retention and Disposal of Documents and Records
Each HealthTrust colleague is responsible for the integrity and accuracy of our organization’s
documents and records, not only to comply with regulatory and legal requirements, but also to
ensure that accurate records are available to support our business practices and actions. No one
may improperly alter, falsify or otherwise tamper with information in any record or document.
Records must never be destroyed in an effort to deny governmental authorities access to records
that may be relevant to a government investigation or inquiry.
Documents and records are retained in accordance with the law of the applicable jurisdiction and
our records management policy, which includes comprehensive retention schedules. Documents
include paper documents such as letters and memos, computer-based information such as email
and computer files on disk or tape and any other medium that contains information about the
organization or its business activities. Records include information in any form that pertains to the
Company’s business and its legal obligations. It is important to retain and destroy records only in
accordance with Company policy, which is oriented toward U.S. law. If laws in other jurisdictions
are stricter than Company policy, such laws must be followed where applicable. No one may
remove or destroy records prior to the date specified in the applicable record retention schedules,
unless certain approvals have been obtained.

Confidential Information
The term “confidential information” refers to non-public, proprietary information about our
organization’s strategies and operations as well as third-party information and patient information.
Improper use or disclosure of confidential information could violate legal and ethical obligations.
HealthTrust colleagues may use confidential information only to perform their job responsibilities.
They shall not share such information with others unless the individuals and/or entities have a
legitimate need to know the information in order to perform their specific job duties or carry
out a contractual business relationship, or if the disclosure is confirmed by the HealthTrust Legal
Department to be required by law.
Confidential information, also referred to as sensitive information, covers virtually anything related
to HealthTrust’s operations that is not publicly known, such as personnel data maintained by the
organization; passwords; pricing and cost data; any individually identifiable patient information,
including patient financial information such as credit card data and social security numbers;
information pertaining to acquisitions, divestitures, affiliations and mergers; financial data;
details regarding any federal, state or local tax examinations; proprietary information; strategic

plans; marketing strategies and techniques; information of our members or clients; information
of a contracted or prospective supplier, subcontractor or independent contractor; non-public
information relating to a HealthTrust advisory board; and proprietary or licensed computer
software. Sensitive data may also include photos and videos.

Use of due care and diligence is required to maintain the confidentiality, availability and integrity
of information assets the Company owns or of which it is the custodian. Because so much of our
business information is generated and contained within our computer systems, it is essential that
each HealthTrust colleague protect our systems and the information contained in them. They must
not share passwords and must review and adhere to our information security policies and standards.

Colleagues must protect such information when it is emailed outside the Company or otherwise
stored, posted or sent through the Internet; stored on portable devices such as laptops, tablets
and mobile phones; or transferred to removable media such as a CD or USB drive. These policies
and standards require, among other things, that the entity to which (or individual to whom)
confidential information is proposed to be sent be validated and that the information be encrypted.
Colleagues must be extremely cautious with social media, taking care to not disclose sensitive
information whether at work or at home and using either a Company or personal system.

Any HealthTrust colleague who knows or suspects confidential information to have been
compromised must report the potential security breach to HealthTrust’s CEO, chief operating
officer (COO), chief information officer, chief legal officer, the HealthTrust ECO or your Local ECO.
If an individual’s employment or contractual relationship with HealthTrust or an individual’s service
on a HealthTrust advisory board ends for any reason, the individual is still bound to maintain the
confidentiality of information viewed, received or used during the employment or other business
relationship with HealthTrust. Any confidential information in a colleague’s possession must be left
with HealthTrust at the end of the employment or other business relationship.

Electronic Media
All communication systems, including but not limited to computers, email, intranet, Internet access,
Company-provided telephones and voice mail, are the property of the organization and are to be
used primarily for business purposes in accordance with our electronic communication policies and
standards. Limited reasonable personal use of HealthTrust communication systems is permitted;
however, users should assume these communications are not private. Users of computer and
telephonic systems should presume no expectation of privacy in anything they create, store, send
or receive on Company computers and telephonic systems and the Company reserves the right to
monitor and/or access communication system usage and content consistent with our policies and

Colleagues may not use Company devices or Company-provided communication channels to access
the Internet or social media to view, post, store, transmit, download or distribute any threatening
materials; knowingly, recklessly or maliciously false materials; obscene materials; or anything
constituting or encouraging a criminal offense, giving rise to civil liability or otherwise violating
any laws. Also, these channels of communication may not be used to send chain letters, personal
broadcast messages or copyrighted documents that are not authorized for reproduction.
Colleagues who abuse our communication systems or use them excessively for purposes other
than Company business may lose these privileges and be subject to disciplinary action, including

Colleagues shall comply with HealthTrust’s information security policies and standards governing
the use of information systems. Only assigned user IDs and “SecureID” cards shall be used.
Individuals are not permitted to share or disclose to any other person any password that is used by
them to access Company systems or information. Portable devices and removable media, such as
laptop computers, PDAs, USB drives, CDs and external hard drives, must be physically secured at
all times. Colleagues shall never use tools or techniques to break or exploit HealthTrust information
security measures or those used by other companies or individuals.

Financial Reporting and Records
We have established and maintain a high standard of accuracy and completeness in documenting,
maintaining and reporting financial information. This information serves as a basis for managing
our business and is important in meeting our obligations to our partners, members, clients,
contracted suppliers, employees and others. It is also necessary for compliance with tax and
financial reporting requirements.
We maintain books and records of our activities consistent with applicable legal requirements,
which in reasonable detail accurately and fairly reflect our transactions and dispositions of assets.
We maintain a system of internal controls designed to provide reasonable assurance that all
transactions are executed in accordance with management’s authorization and are recorded in
conformity with generally accepted accounting principles (GAAP).
We diligently seek to comply with all applicable auditing, accounting and financial disclosure laws,
including but not limited to the U.S. Securities Exchange Act of 1934 and the Sarbanes-Oxley Act
of 2002. Anyone having concerns regarding accounting or auditing matters should report such
matters to the HealthTrust CEO, Chief Financial Officer, the HealthTrust ECO or your Local ECO, or
by calling the HealthTrust Ethics Line.

Patient Information
“Protected health information” or “PHI” is health information that is specific to an individual
patient. PHI is protected in the U.S. under the Health Insurance Portability and Accountability
Act (HIPAA) and related laws, and in the U.K. under the Data Protection Act 1998. PHI is defined
very broadly under HIPAA and includes information relating to the physical or mental health or
condition of an individual, the provision of healthcare to an individual, or payment for the provision
of healthcare to an individual.
All employees at HealthTrust that may possibly encounter PHI in their work must be trained to
recognize PHI.

Most HealthTrust employees have no need to receive PHI to perform their job responsibilities.
However, in some cases PHI may be included inadvertently in data sets provided to or accessed
by an employee while performing services for a potential or existing member or client. If this
occurs, management and the Legal Department must be informed immediately to ensure proper
procedures are followed, including notification to the member or client, and the return and/or
destruction of the data in its entirety, or removal of PHI from it.

While infrequent, occasionally an employee must receive PHI in order to perform his or her job
responsibilities. In such cases, management and the Legal Department must be informed in
advance to ensure that the employee will receive only the minimum amount of PHI necessary to
do the job and only for a proper purpose under the law. The employee must also be trained on
the proper processes for receipt, storage, distribution and destruction of such data. The Legal
Department will further determine whether a business associate agreement is needed, to be put
in place prior to access or receipt of PHI by such employees.

We realize the sensitive nature of this information and are committed to maintaining its
confidentiality. If you have any concerns regarding this matter, please contact the Legal
Department, your Local ECO or privacy officer, or the HealthTrust ECO.

Business courtesies are things such as gifts, entertainment, food and beverages given or received
by business contacts, to establish cordial relations and promote their respective companies. This
section does not pertain to actions between HealthTrust and its colleagues, or among colleagues.
Also, this section should not be considered in any way as an encouragement to provide, solicit or
receive any type of entertainment, food and beverages, or gift. In some cases, attempts are made
to disguise bribery through the giving or receiving of lavish business courtesies. This is prohibited.
All business courtesies extended or received must be modest in value, reasonable and customary
for the location and in compliance with applicable law. Value limitations are shown below for the
U.S., U.K. and P. R. China. For other countries, see Company policies. All business courtesies must
be reported to the HealthTrust ECO or your Local ECO.

Additional rules apply to the giving of a business courtesy to a “foreign official,” broadly defined
under the U.S. Foreign Corrupt Practices Act and to the receipt of business courtesies within P.R.
China or by P.R. China nationals anywhere in the world. See your Local ECO or the HealthTrust ECO
for more information.
See Policies HT.005 – Business Courtesies Given by HealthTrust to Others; HT.006 – Business
Courtesies Received by HealthTrust Colleagues from Others; and HT.020 – Global Anti-corruption.

Limitations on Value of Business Courtesies

Limitations on Gifts
Gifts may not exceed a total value per instance and per calendar year of $75 in the U.S. or £25 in
the U.K., for recipients from those countries. For gifts given or received in P.R. China or involving
P.R. China nationals, the value may not exceed RMB 100 per instance or RMB 200 per calendar year.
A gift may not be in the form of cash, cash equivalents, stock, checks, notes, warrants or other
instruments. Gift cards are acceptable if not redeemable for cash and if the value of all such cards
given or received by one individual from a particular company in one year does not exceed $20 for
recipients in the U.S. or £15 in the U.K. Gift cards may not be given or received where the laws of
P.R. China apply or to “foreign officials” as defined under the U.S. Foreign Corrupt Practices Act,
other governmental officials, or potential sources of referrals of patients to healthcare facilities
of HealthTrust members. Gifts other than consumable gifts offered to HealthTrust (rather than an
individual) may be accepted only with the written consent of the CEO.

Perishable or Consumable Gifts
Perishable or consumable gifts given by a business contact to a HealthTrust department or
group are discouraged. Although such gifts are not subject to reporting requirements or specific
limitations, they must be modest and reasonable in value and customary for the location. Similarly,
if such a gift is given to a HealthTrust colleague who in turn makes it available in a public area
of the office or facility for his or her department or group, it is not subject to any reporting
requirements or specific limitations if modest, reasonable and customary for the location.
Limitations on Expenditures for Food and Beverages, and Entertainment
No event that might be considered lavish or in questionable taste may be offered or accepted.
Expenses for food and beverages may not exceed a total value per instance of the following
amounts: $150 for events in the U.S.; £250 for events in the U.K.; and RMB 250 for events that take
place in P.R. China or that involve P.R. China nationals. The limitations set out in this paragraph do
not apply to food and beverages served during a business meeting. As a general rule, a restaurant
meal is usually considered to be a business courtesy and a meal served in an office is usually
considered to be part of a business meeting. Expenses for entertainment such as a sporting or
cultural event may not exceed a total value per instance of $150 for events in the U.S.; £250 for
events in the U.K.; and RMB 100 for events that take place in P.R. China or that involve P.R. China

Limitations on Expenditures for Travel
Costs of transportation and lodging are similarly restricted. HealthTrust does not pay such costs
for its business contacts and no offer from a business contact to pay such costs for a HealthTrust
colleague may be accepted. Limited exceptions to this prohibition are outlined in our policies and
include HealthTrust’s payment of its members’ expenses for the HealthTrust conference which is
a benefit of membership; and instances where a HealthTrust colleague is acting as a speaker at a
large industry or professional event or supplier event, or where he or she serves as a member of a
governing or advisory body of a professional association. No colleague may speak on behalf of, or
represent, any supplier.

Overall Total Expenditures Per Instance and Per Year
In addition to the limits referenced above, our policies specify a total expenditure per instance
amount that accounts for occasions that involve more than one category of spend, such as a meal
followed by an entertainment event in the same evening, or a meal where a gift is presented. The
total expenditure per instance limit in the U.S. is $150, £250 in the U.K., and RMB 350 in P.R. China.
The total expenditure amount per calendar year that HealthTrust may give to any business contact,
or that a HealthTrust colleague may receive from a representative of any one company or company
division is $500 in the U.S., £500 in the U.K., and RMB 700 in China.

Other Rules on Business Courtesies
Extending Business Courtesies to Government Employees, Representatives or Officials
Special laws apply if an employee is considering extending a business courtesy to a person who
is an official of, employed by or represents any government; an entity owned or controlled, in
whole or in part, by a government; or a public international organization such as the World Health
For example, the governments of the U.S. and U.K. have strict laws regarding gifts, meals and other
business courtesies for their employees. HealthTrust does not provide any gifts, entertainment,
meals or anything else of value to any employee of the executive branch of the U.S. federal
government or its fiscal intermediaries if they are acting in an oversight, investigative, enforcement
or legal role. In other cases, meals valued at no more than $20 per event, not to exceed $50 per
calendar year, may be offered, in addition to minor refreshments in connection with business
discussions with employees of the U.S. federal government. With regard to gifts, meals and other
business courtesies involving any other category of government official or employee, colleagues
must determine the particular rules applying to any such person and carefully follow them. Please
consult with your Local ECO, the HealthTrust ECO or the HealthTrust Legal Department before the
event takes place.

Extending Business Courtesies to Physicians who are Potential Referral Sources
The giving or offering of any meal, entertainment or gift by a HealthTrust colleague to physicians
or others who are in a position to refer patients to a healthcare facility of a HealthTrust member
or client must be undertaken in accordance with our policies as well as the policies of the member
or client. Colleagues must consult our policies and the HealthTrust ECO prior to extending any
business courtesy or token of appreciation to a potential referral source. See Policy HT.019 –
Agreements with Professionals Who May Be Referral Sources and similar policies applicable to
HealthTrust Europe.

Quiet Period
This quiet period relates to a supplier who has responded or intends to respond to a request for
proposals issued by HealthTrust (or invitation to tender/ITT issued by HTE) in a particular product
category. It begins with the issuance of the RFP or ITT and ends with the award or renewal of the
contract. During that time, no business courtesy may be accepted from such a supplier by the
advisory board as a group charged with evaluating that category, or any person on the HealthTrust
negotiating team, except that HealthTrust or HTE employees may share a meal with such a supplier
if the parties pay their own costs. At other times, regular business courtesies rules as set out above
in this section apply.
We operate in a highly competitive environment. Our competitive activities must conform to the
high standards of integrity and fairness reflected in this Code of Conduct. The Company requires
compliance with antitrust, anti-monopoly and competition law and similar legislation governing
competitive activities in the various jurisdictions in which we operate. Compliance with the
Company’s written policies governing interactions with competitors, our members, clients and
contracted and potential suppliers is also required.

Global Anti-corruption and Bribery
Bribery in connection with HealthTrust’s business is prohibited, whether direct, indirect or
carried out by HealthTrust colleagues, intermediaries or other third parties. Payment of a bribe
involves offering, promising or giving a financial or other advantage with the intent to induce or
reward improper conduct. Offering, seeking or receiving bribes may be a criminal offense.
It is our policy to comply with all anti-corruption and bribery laws that apply to Company operations,
including the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act, similar laws in P.R.
China and any other jurisdiction where HealthTrust conducts business. Our organization has a global
anti-corruption policy (Policy HT.020 – Global Anti-corruption) that sets out rules for our business
dealings with any person who is an official of, employed by or represents any government, an entity
owned or controlled by a government or a public international organization such as the World Health
Organization. That policy prohibits colleagues from giving, offering or authorizing the provision of
anything of value to, or for the benefit of, a government official to obtain or retain business, secure
any other business advantage or to obtain beneficial governmental treatment, except as specifically
permitted in the policy. Before offering or giving anything of value to an individual who may be an
official, employee or representative of a government or state-owned or -controlled entity, colleagues
must comply with all Company policies.

The U.K. Bribery Act 2010 has worldwide scope, applying to conduct within or outside the U.K. if
an entity has a close connection with the U.K., as HealthTrust may have with its U.K. subsidiary
HealthTrust Europe. The Bribery Act requires us to exercise care in our dealings with other persons
in connection with HealthTrust’s business. This includes but is not limited to employees, consultants,
overseas agents, members, clients, suppliers and subsidiaries. The Bribery Act prohibits providing
any financial or other benefit to individuals or businesses in public and private enterprise, as well as
to foreign public officials, for the purpose of influencing the improper performance of an activity or
function. It also includes the offense of failing to prevent bribery, so HealthTrust must ensure that it
has adequate procedures in place to ensure prevention, one aspect of which is this Code of Conduct
and its associated policies.

Similarly, in P.R. China, criminal law prohibits giving and receiving property in order to obtain
an improper benefit, including an unfair commercial advantage. Under P.R. China law, bribery is
typically divided into two categories – official bribery and commercial bribery. “Official bribery”
involves bribes to a government agency, governmental officials or personnel performing public
duties in state-owned enterprises or private companies. “Public duties” include the carrying out
of organizational, leadership, supervisory and management functions on behalf of enterprises or
institutions of any kind owned in whole or in part by the state. “Commercial bribery” means the
offering or receiving of bribes between non-governmental agencies, companies or personnel.
Individuals as well as entities can be prosecuted for the crime of offering or accepting bribes.
Chinese unfair competition law also prohibits commercial bribery, defined under that law as
giving, receiving or demanding things of value in connection with the sale or purchase of goods or
services. The granting of secret, off-record payments or kickbacks to any individual or company is
considered to be a bribe.

Before offering anything of value to any person or entity that is doing business with or seeks to
do business with HealthTrust, a HealthTrust colleague must follow the organization’s policies on
anti-corruption and business courtesies. Please contact the HealthTrust ECO, your Local ECO or the
HealthTrust Legal Department immediately if you have concerns about anti-corruption or bribery
issues in any jurisdiction.

Antitrust and Unfair Competition
Antitrust, anti-monopoly and competition laws are designed to create a level playing field in the
marketplace and promote fair competition. These laws could be violated by discussing HealthTrust
business with a competitor (such as disclosing the terms of supplier relationships), allocating
markets among competitors or agreeing with a competitor to refuse to deal with a supplier.
At trade association meetings or in other settings, colleagues must refuse to participate in
discussions with competitors regarding prohibited subjects. Prohibited subjects include any aspect
of pricing, key costs and marketing plans. If a competitor raises a prohibited subject, colleagues
must end the conversation immediately. Colleagues must document their refusal to participate
in the conversation by requesting that their objection be noted in an appropriate manner (e.g.,
meeting minutes) and, in any case, they must notify the HealthTrust Legal Department of the
Because HealthTrust operates in several jurisdictions and the antitrust and competition laws
can depend on local market conditions, it is not practical to adopt written policies to govern all
situations. Colleagues should consult with their supervisors or the HealthTrust Legal Department
for guidance concerning competitive activities, laws and policies related to their areas of

Gathering Information About Suppliers or Competitors
Colleagues should avoid seeking or receiving confidential information about current or potential
suppliers or competitors through improper means, if they know or have reason to believe the
information is confidential. Confidential information can include information that is the property
of the supplier or competitor such as prices charged; cost of goods, equipment, supplies or labor;
terms of contracts; and other non-public information that the owner of the information seeks to
keep confidential. As a HealthTrust member or client seeks best pricing, it may have or obtain
information such as pricing from a supplier that does not have a HealthTrust contract and seek to
share that information with HealthTrust. The HealthTrust member or client should not disclose such
information to HealthTrust and HealthTrust employees should not accept it, if the disclosure would
be a violation of an agreement between the HealthTrust member or client and the non-contracted
Marketing and Advertising
Consistent with laws and regulations that govern such activities, we use marketing and advertising
activities to increase awareness of our services; provide information to our members, clients and
potential members or clients and to our contracted and potential suppliers; educate the public;
and recruit new colleagues. We strive to present only truthful, informative and non-deceptive
information in these marketing and advertising materials and announcements.
While it is permissible to compare and contrast our services with those of our competitors,
it is against Company policy to intentionally disparage other persons or businesses based on
information that is untrue, or not known to be true, or to intentionally interfere with contractual
and business relationships of another business through wrongful means. This does not prevent our
competing for the business of those who may have a relationship with a HealthTrust competitor in
a fair and non-deceptive manner.


A conflict of interest may occur if a HealthTrust colleague’s outside activities, personal interests,
financial interests or other private interests, or those of someone in his or her family, interfere
or appear to interfere with the colleague’s ability to make objective decisions in the course of
his or her responsibilities to HealthTrust. A conflict may also arise if a colleague takes actions or
has interests that may cause the colleague to compete with HealthTrust or misuse HealthTrust
resources or confidential information, or if a colleague or family member receives anything that
could be perceived as an improper benefit as a result of his or her position or affiliation with
HealthTrust. Having a financial interest in a contracted or prospective HealthTrust supplier or a
competitor of HealthTrust, or acting as a speaker or representative on behalf of such a company,
is of special concern. HealthTrust colleagues are obligated to ensure they remain free of conflicts
of interest, and even the appearance of conflicts, in the performance of their responsibilities at
These restrictions also apply to our advisory board members. We have approximately ten advisory
boards made up of representatives of our membership who have expertise in the product or service
category over which the board has authority. These boards play a key role in our decision-making
in awarding HealthTrust contracts.

We manage conflicts by requiring that they be disclosed so that they may be addressed.
HealthTrust decision-makers must disclose conflicts as they arise to their supervisor, advisory
board lead, Local ECO or the HealthTrust ECO, and they must annually certify as to their conflicts
status. If a conflict arises, it is mitigated by taking action such as excluding the conflicted
colleague from HealthTrust decision-making processes that relate to the conflict or requiring
divestiture of the interest that gave rise to the conflict if applicable. If colleagues have any
questions about whether an outside activity or private interest may constitute a conflict, they must
discuss the matter with their supervisor, the HealthTrust ECO or their Local ECO. If advisory board
members have questions, they should consult with their advisory board lead.
We are also alert to the possibility of institutional conflicts, which could occur if HealthTrust itself
or one of our equity partners has an interest in a supplier. Consideration for a HealthTrust contract
award for such a supplier would follow the usual HealthTrust contracting process, with additional
actions taken to mitigate the conflict. Representatives of the conflicted equity partner would be
excluded from advisory board meetings where the supplier or product category will be discussed,
or excluded from decision-making at such meetings. See Policy HT.003 – Conflict of Interest.


HealthTrust has always been dedicated to sustainability. Our program today touches on dimensions
such as clean energy and the management of facilities, waste and chemicals. At the heart of
our sustainability initiative is our Environmentally Preferable Purchasing Program that factors
ecological stewardship into product sourcing and contract awards. For a product to be considered
environmentally preferable, it must be made by manufacturers committed to reducing waste
throughout a product’s life cycle, and must not contain toxic materials that can contribute to
negative health issues, such as carcinogens.


HealthTrust operates in three countries and many U.S. states. These operations are carried out
pursuant to the federal, state and local laws and regulations of the various jurisdictions. We have
developed policies and procedures to address many legal and regulatory requirements. Although it
is impractical to develop policies and procedures that encompass the full body of applicable law,
standards, conditions and regulations, all of these requirements must nevertheless be followed.
There is a range of expertise within the organization, including in-house counsel and numerous
functional experts, who should be consulted for advice concerning human resources, legal,
regulatory, financial and other requirements.
Anyone aware of violations or suspected violations of laws, regulations or Company policies and
procedures, or violations of this Code, must report them immediately to a supervisor or member of
management, the HealthTrust Legal Department, your Human Resources manager, your Local ECO,
the HealthTrust ECO or the Ethics Line.

Audits, Surveys, Inspections
From time to time, government agencies, accrediting bodies and other entities may conduct audits,
surveys or inspections related to our facilities and operations. Any such audit, survey or inspection
should be reported through your chain of command and to the Local ECO or the HealthTrust ECO
immediately. The scope of matters related to such an activity is extremely significant and broader
than the scope of this Code of Conduct, but here are some general guidelines: In preparation for,
during and after surveys, HealthTrust colleagues must deal with all government, accrediting and
external agency survey bodies in a direct, open and honest manner. No action should ever be taken
that would mislead them; we respond with openness and accurate information. We do not conceal,
destroy or alter any documents; lie or make misleading statements; or cause or attempt to cause


another colleague to do so. Colleagues aware of violations or suspected violations of our obligation
to provide truthful and factual representations and responses to auditing, survey or inspecting
agencies must report the concern immediately through their chain of command and to their
Local ECO.

Fraud is the use of deception by someone intending to obtain an advantage, avoid an obligation,
or cause a loss to another party. It includes offenses such as theft, embezzlement and
misappropriation of assets. Examples include making a false claim for reimbursement of expenses
or overtime pay not earned; requesting payment for services not rendered or goods not delivered;
falsifying Company documents; and misappropriating funds, supplies, data or other assets. Fraud
prevention at HealthTrust is everyone’s responsibility. Supervisors should ensure they are familiar
with the types of improprieties that could occur in their area and should establish internal controls.
They should train their employees on identified risks and ensure that appropriate audits are
performed. Employees must implement those controls and suggest additional ones, if warranted.
All employees must report any suspected fraud to their supervisor, a member of management, the
HealthTrust ECO, their Local ECO or the Ethics Line.

Government Relations and Political Activities
HealthTrust strives to comply with all laws governing participation in government relations and
political activities in the jurisdictions where we operate. As a general policy, HealthTrust funds or
resources are not contributed directly to individual political campaigns, political parties or other
organizations that intend to use the funds primarily for political campaign objectives. HealthTrust
resources include financial and non-financial assets such as work time, telephones, office space and
email to solicit for a political cause or candidate.
HealthTrust may engage in public policy debate only in those limited circumstances where it has
special expertise that can inform the public policy formulation process. When HealthTrust may
be directly impacted by a public policy decision, it may provide relevant, factual information
about the impact of such decisions on organizations such as ours. In articulating positions, the
organization only takes positions that it believes can be shown to be in the larger public interest.
The organization encourages trade associations with which it is associated to do the same. At
times, HealthTrust may ask a colleague to make personal contact with government officials or
to write a letter to present our position on specific issues. In addition, it may be part of the role
of some HealthTrust supervisors to interface with government officials. If a colleague is making
these communications or interacting on behalf of HealthTrust, he or she must be familiar with any
regulatory constraints and observe them. Guidance should be sought from the HealthTrust Legal
Department in such cases.

Hiring of Former or Current Government Employees

The recruitment and employment of former or current government employees may be impacted
by conflict of interest regulations. Colleagues should consult with their Human Resources manager
prior to any such recruitment and hiring.
Ineligible Persons
HealthTrust does not contract with or employ any individuals or entities that are currently excluded
or ineligible to participate in U.S. federal healthcare programs; suspended or debarred from U.S.
federal government contracts; or currently on any U.S. state government exclusions list.
We search the U.S. General Service Administration’s exclusion records in the System for Award
Management, the U.S. Department of Health and Human Services’ Office of the Inspector General
and U.S. General Services Administration’s lists and applicable state exclusion lists of such
ineligible persons before entering into or renewing agreements with third parties, in accordance
with Company policy. All such entities and individuals must represent to HealthTrust that they are
not ineligible at the time of contracting, and they must agree to inform HealthTrust immediately of
any change in status. If HealthTrust becomes aware of any supplier becoming ineligible during the
term of its agreement with HealthTrust, we will terminate the agreement.

Insider Information and Securities Trading

In the course of colleagues’ employment or other business relationship with HealthTrust, they
may become aware of non-public information about HealthTrust, a HealthTrust member, client or
affiliate or a contracted or prospective supplier that could be material to an investor’s decision
to buy or sell such company’s securities. Non-public, material information may include marketing
strategy, financial results, plans for mergers or acquisitions, the awarding of a large contract or
other business matters. Colleagues may not discuss this type of information with anyone outside
of the organization. Within the organization, colleagues should discuss this information only on a
“need to know” basis as required for the performance of job duties.
Colleagues may not buy, sell, transfer, gift or effect other transactions of publicly registered and
traded securities of the company to which the information relates, or discuss that information with
others, until the information is considered to be public. Information is considered public on the
second trading day after the date of a general release of the information to the media.
Interactions with Physicians
U.S. federal and state laws govern the relationship between hospitals and physicians who may
refer patients to facilities of our members or clients. The applicable federal laws include the Anti-kickback Law and the Stark Law.


All arrangements with physicians (such as speaking engagements, participation on an advisory
board, employment or professional services agreements, supplier agreements, etc.) must be
properly structured to ensure compliance with laws and company policy, and be diligently
administered, to avoid violations of law. Most arrangements must be in writing and approved
by the Legal Department. Failure to meet all requirements of these laws can result in serious
consequences. See Policy HT.019 – Agreements with Professionals Who May Be Referral Sources
and similar policies applicable to HealthTrust Europe. Keeping in mind that it is essential to be
familiar with the laws, regulations and policies that govern our interactions with physicians, two
overarching principles govern these relationships:
No payments for physician referrals to a member or client healthcare facility are allowed. Such
healthcare facilities accept patient referrals and admissions based solely on patients’ medical
needs and the facility’s ability to render the needed services. They may not pay or offer to pay
anyone — colleagues, physicians, or other persons or entities — directly or indirectly, for referral of
No payments for a physician’s referral to another facility are allowed. No healthcare facility or
organization, or any person acting on its behalf, is permitted to solicit or receive anything of value,
directly or indirectly, in exchange for the referral of patients. Similarly, when a member or client
facility makes patient referrals to another healthcare provider, the member or client facility may
not take into account the volume or value of referrals that healthcare provider has made (or may
make) to that facility.


HealthTrust colleagues shall respect the valid intellectual property rights that others may have
under patent, copyright, trade secret and other applicable laws. Unauthorized use of valid
intellectual property rights of others is prohibited.

HealthTrust colleagues may only copy and/or use copyrighted materials of others in accordance
with a valid license, applicable law and with the owner’s permission, if applicable.
Rights to Developments
Any work of authorship, invention or other creation (Development) of a colleague within the scope
of the colleague’s employment with HealthTrust shall be considered the property of HealthTrust,
including any patent, trademark, copyright, trade secret or other intellectual property right in the
Development. Whether something is considered to have been developed during the scope of a
colleague’s employment depends on a number of factors, including:
• The nature of the colleague’s work
• Whether the Development is related to HealthTrust’s business
• Whether the colleague was directed to produce the Development as part of his or her work
• Whether the colleague utilized HealthTrust intellectual property or resources at least in part
to make the Development, and/or
• Whether the colleague created the Development while being paid by HealthTrust
If any Development created is copyrightable or patentable, it will be considered a “Work for Hire”
under the U.S. Copyright Act or U.S. Patent Act, a “Copyright Work” under the U.K. Copyright,
Designs and Patents Act of 1988 or similarly designated by other applicable law, with HealthTrust
being considered to be the author and owner of such work.
When creating Developments for HealthTrust, colleagues shall respect the intellectual property
rights of others. Any works or inventions created by colleagues prior to employment by
HealthTrust shall be disclosed to HealthTrust upon commencement of employment, and HealthTrust
management and Legal Department approval shall be obtained prior to any use of these works or
inventions in a Development for HealthTrust.
By signing the acknowledgment to this Code of Conduct by hand or electronically, a colleague
specifically agrees to be bound by these provisions of the Code of Conduct. As such, the

acknowledgment serves as an assignment by the named colleague to HealthTrust of all right,
title and interest in all Developments created by the colleague within the scope of his or her
employment, as well as an appointment of the chief legal officer of HealthTrust as the colleague’s
attorney-in-fact to execute documents on his or her behalf for the foregoing purposes.
Colleagues shall assist HealthTrust in obtaining and enforcing intellectual property rights in their
Developments, while employed by HealthTrust and after termination of employment.


Diversity and Equal Employment Opportunity

HealthTrust actively promotes diversity in its workforce at all levels of the organization. We are
committed to providing an inclusive work environment where everyone is treated with fairness,
dignity and respect. We are accountable to one another for the manner in which we treat each
other and for the manner in which people around us are treated. We are committed to recruiting
and retaining a diverse staff reflective of the communities we serve. We regard laws, regulations
and policies relating to diversity as a minimum standard. We strive to create and maintain a
setting in which we celebrate cultural and other differences and consider them strengths of the
HealthTrust is an equal opportunity workforce and no one shall discriminate against any individual
with regard to race, color, religion, sex, national origin, age, disability, sexual orientation, gender
identity, genetic information, veteran status or any other status that is protected under the laws of
the applicable jurisdiction, with respect to any offer, term or condition of employment. We make
reasonable accommodations to the known physical and mental limitations of qualified individuals
with disabilities.

Harassment and Workplace Violence

Each HealthTrust colleague has the right to work in an environment free of harassment and
disruptive behavior. We do not tolerate harassment by anyone based on the diverse characteristics
or cultural backgrounds of those who work with us. Degrading or humiliating jokes, slurs,
intimidation or other harassing conduct is not acceptable in our workplace.
Sexual harassment is prohibited. This prohibition includes unwelcome sexual advances or requests
for sexual favors in conjunction with employment decisions. Moreover, 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 HealthTrust.


Harassment also includes incidents of workplace violence. Workplace violence includes robbery
and commercial crimes, stalking, violence directed at the employer or another employee, terrorism
and hate crimes committed by current or former colleagues. Colleagues who observe or experience
any form of work-related harassment or violence should report the incident to their supervisor,
Human Resources manager, another member of management, the HealthTrust ECO, your Local ECO
or the Ethics Line.

Health and Safety

All HealthTrust facilities comply with all applicable government regulations and rules, HealthTrust
policies and required facility practices that promote the protection of workplace health and safety.
Our policies have been developed to protect our colleagues from potential workplace hazards.
Colleagues must become familiar with and understand how these policies apply to their specific
job responsibilities and seek advice from their supervisors whenever they have a question or
concern. It is important that each colleague immediately advise his or her supervisor of any serious
workplace injury or any situation presenting a risk of injury so timely corrective action may be
taken to resolve the issue.

License and Certification Renewals

HealthTrust does not allow any colleague, independent contractor or privileged practitioner to
work without a valid credential such as a current professional license, registration or accreditation,
if one is required by their position description. Colleagues and independent contractors in such
positions are responsible for maintaining the current status of their credentials. They shall comply
at all times with legal and regulatory requirements applicable to their respective disciplines and
jurisdictions. To assure compliance, HealthTrust may require evidence of the individual having a
current license or credential status.

Personal Use of HealthTrust Resources

It is the responsibility of each HealthTrust colleague to preserve our organization’s assets,
including time, materials, supplies, equipment and information. Organization assets are to be
maintained for business-related purposes. As a general rule, the personal use of any HealthTrust
asset without prior supervisory approval is prohibited. The occasional use of items such as
copying machines and telephones, where the cost to HealthTrust is insignificant, is permissible.
Any community or charitable use of HealthTrust resources must be approved in advance by
one’s supervisor. Any use of organization resources for personal financial gain unrelated to the
Company’s business is prohibited.

Relationships Among HealthTrust Colleagues

In the normal day-to-day functions of an organization like HealthTrust, issues arise related to how
people in the organization interact with one another. It is impossible to foresee all of these and
many do not require explicit treatment in our Code of Conduct; however, a few routinely arise.
One involves gift-giving among colleagues for certain occasions. While we wish to avoid any strict
rules, no one should ever feel compelled to give a gift to anyone and any gifts offered or received
should be appropriate to the circumstances. A lavish gift to anyone in a supervisory role would
clearly be inconsistent with Company policy. Another situation that routinely arises is a fundraising
or similar effort undertaken by individual colleagues, in which no one should ever be compelled to
participate. Similarly, when the Company determines to support charitable organizations such as
the United Way, no colleague should be compelled to contribute to the charitable organization nor
should there be any workplace consequences for such non-participation.

Substance Abuse and Mental Acuity

We are committed to an alcohol- and drug-free work environment. All colleagues 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 one’s system or using, possessing or selling
illegal drugs while on HealthTrust work time or property may result in immediate termination. We
may use drug testing as a means of enforcing this policy.
It is also recognized that individuals may be taking prescription or over-the-counter drugs that
could impair judgment or other skills required to perform their job. A colleague with questions
about the effect of such medication on his or her own performance or who observes an individual
who appears to be impaired in the performance of his or her job, must immediately consult with a


Program Structure

The HealthTrust Ethics and Compliance Program is intended to demonstrate in the clearest
possible terms the absolute commitment of the organization to the highest standards of ethics and
compliance. The elements of the program include setting standards (this Code and related policies
and procedures), communicating the standards, providing a mechanism for reporting potential
exceptions, monitoring and auditing, and maintaining an organizational structure that supports the
furtherance of the program. Each of these elements is detailed below.
These elements are supported at all levels of the organization. Providing direction, guidance and
oversight is the HealthTrust Ethics and Compliance committee made up of HealthTrust senior
management including the HealthTrust CEO, chief legal officer, the HealthTrust ECO, and the ethics
and compliance officers of several of our partners.


The HealthTrust ECO is responsible for the day-to-day direction and implementation of the Ethics
and Compliance Program. This includes developing resources (such as policies and procedures,
training programs and communication tools) for and providing support (such as handling matters
that come in through the Ethics Line, conducting program assessment and providing advice) to
colleagues, Local ECOs and others.
The HealthTrust CEO is ultimately responsible for HealthTrust’s ethics and compliance matters, as
our “Responsible Executive.” He is called upon to direct the HealthTrust ECO in policy and training
development efforts, conduct monitoring and auditing as appropriate and provide advice.
Our Local ECOs play a key role in ensuring the successful implementation of our Ethics and
Compliance Program. They are responsible for distributing standards, ensuring training is
conducted, monitoring, ensuring compliance with applicable laws, responding to inquiries and
audits, investigating and resolving regional Ethics Line cases and otherwise administering the
Ethics and Compliance Program in their respective regions.

Another important resource who may be able to address issues arising out of this Code of Conduct
is your Human Resources manager. Human Resources managers are highly knowledgeable about
many of the compliance risk areas described in this Code of Conduct that pertain to employment
and the workplace and are responsible for ensuring compliance with various employment laws.
If a concern relates to specific details of an individual’s work situation, rather than larger issues
of organizational ethics and compliance, your Human Resources manager may be the most
appropriate person to contact. Because we promote the concept of management autonomy at
our facilities, efforts should be made to resolve workplace conduct and employment practice
issues through the individual’s supervisor and the Human Resources manager. Human Resources
managers also assist in investigating and resolving Ethics Line cases that relate to workplace
conduct and employment practice issues.

All of these individuals or groups are prepared to support HealthTrust colleagues in meeting the
standards set forth in this Code.

Setting Standards
With respect to our Ethics and Compliance Program, we set standards through this Code of
Conduct, ethics and compliance policies and procedures and, occasionally, through other guidance
such as Compliance Alerts and advisory memoranda. It is the responsibility of each individual to be
aware of the policies, procedures, handbooks and other materials that pertain to his or her work,
and to follow they guidance they provide.


Training and Communication

Comprehensive training and education has been developed to ensure that colleagues throughout
the organization are aware of the standards that apply to them. Code of Conduct training is
conducted at the time an individual joins the organization and annually for all colleagues.
Additional training in certain areas of compliance risk may also be required of some individuals, as
appropriate for their role at HealthTrust.
All ethics and compliance training is required to be recorded in the Company’s learning
management system (HealthStream) or other similar system. Through HealthStream, system
administrators and ECOs track colleagues’ compliance with their training requirements and report
such information as necessary.
Many resources regarding our ethics and compliance program are available to HealthTrust
colleagues on our intranet and to the general public on the Internet at HealthTrust Ethics and
Compliance and, for HealthTrust Europe, at HealthTrust Europe Ethics and Compliance. We
encourage all colleagues to frequently visit their home site.

Resources for Guidance and Reporting Concerns

To obtain guidance on an ethics or compliance issue or to report a concern, individuals may choose
from several options. We encourage the resolution of issues, including human resources-related
issues (e.g., payroll, fair treatment and disciplinary issues), at the local level. It is an expected
good practice, if one is comfortable and views it as appropriate under the circumstances, to raise
concerns first with one’s supervisor. If this is uncomfortable or inappropriate, the individual may
discuss the situation with his or her Local ECO, if applicable, or the HealthTrust ECO, Human
Resources manager, or another member of management at the facility or in the organization.

Individuals are always free to contact the Ethics Line.

HealthTrust makes every effort to maintain, within the limits of the law, the confidentiality of the
identity of any individual who reports concerns or possible misconduct. There is no retribution or
discipline for anyone who reports a concern in good faith. However, any colleague who deliberately
makes a false accusation for the purpose of harming or retaliating against another colleague may
be subject to discipline.

Personal Obligation to Report

We are committed to ethical and legal conduct that is compliant with all relevant laws and
regulations and to correcting wrongdoing wherever it may occur in the organization. Each
colleague has an individual responsibility for reporting any activity by any colleague, independent
contractor, subcontractor, service provider or supplier that appears to violate applicable laws,
rules, regulations, our policies or this Code. If a matter that poses serious compliance risk to the
organization is reported and the reporting individual doubts the issue has been given sufficient
or appropriate attention, or remains unresolved, the individual should report the matter to higher
levels of management or to the Ethics Line until satisfied that the full importance of the matter has
been recognized.

Internal Investigations of Reports

We are committed to investigating all reported concerns promptly and confidentially to the
extent possible. The HealthTrust ECO coordinates any findings from regional or corporate-led
investigations and recommends corrective action or changes that need to be made. We expect all
colleagues to cooperate with investigation efforts.

Corrective Action

Where an internal investigation substantiates a reported violation, it is the policy of the
organization to initiate corrective action, including (as appropriate) notifying the relevant
government agency if any, instituting disciplinary action and implementing systemic changes to
prevent a similar violation from recurring in the future.


Any employee who violates the Code may be subject to disciplinary action. The precise discipline
utilized will depend on the nature, severity and frequency of the violation and may result in any or
all of the following actions:

Oral warning
Written warning
Written reprimand
Measuring Program Effectiveness

We are committed to assessing the effectiveness of our Ethics and Compliance Program through
various efforts, including periodic audits conducted by the Internal Audit Department. The
HealthTrust ECO routinely undertakes monitoring efforts in support of policies and compliance
in general. The Local ECOs conduct reviews of ethics and compliance programs designed to
assess regional implementation of the Code, policies and procedures, Ethics Line and related
investigations, and monitoring efforts.

Most of these methods of assessment result in reports of findings by the reviewers and corrective
action plans. Through these reviews, we are continuously assessing the effectiveness of the
Program and finding ways to improve it.

Acknowledgment Process

HealthTrust requires all employees, as a condition of employment, to acknowledge (by signature or
electronic means) their review of the Code, confirm they understand that it represents mandatory
policies of HealthTrust and agree to abide by it. New employees must receive Code of Conduct
training within 30 days of employment. Each HealthTrust employee is also required to participate
in annual Code of Conduct training. Advisory board members are required to participate in annual
training on those aspects of this Code that are germane to their work as advisory board members.
Records of such training must be retained by the ECO or Local ECO who conducts or manages the
training and copies of such records must be sent to and retained by the HealthTrust ECO.
Adherence to and support of HealthTrust’s Code of Conduct and participation in related activities
and training is considered in decisions regarding hiring, promotion and compensation for all
candidates and colleagues.


If your main place of work is within a healthcare facility, you should follow the Code of Conduct of
your healthcare facility rather than this Code of Conduct.
If, in the performance of your job, you regularly visit one or more healthcare facilities and/or are
temporarily stationed at or work from a healthcare facility, you must comply with the guidance
below to the extent applicable to your work in a facility.
(If your job does not require you to visit or work temporarily in a healthcare facility, you do not
need to review the below and can skip to the last section of this Code of Conduct.)


Quality of Care and Patient Safety

Some HealthTrust colleagues are temporarily based at and/or visit the healthcare facilities of our
members or clients where they may have contact with patients. We treat any patient we encounter
with respect and dignity. As a general principle, our members and clients aspire to a standard of
excellence for the entire team at each of their facilities and are committed to the delivery of safe,
effective, efficient, compassionate and satisfying care and services. HealthTrust is part of that
team. HealthTrust colleagues who encounter patients must be aware of our members’ and clients’
commitment to patient rights and their privacy practices in conformity with all applicable state and
federal laws, including but not limited to HIPAA in the U.S. and the Data Protection Act 1998 in the
This commitment to quality of care and patient safety is an obligation of all HealthTrust colleagues
who encounter patients in their work. In any circumstance where a colleague questions whether
quality or patient safety commitments are being fully met, that individual is obligated to raise this
concern through appropriate channels. Such channels include the colleague’s designated contact
at the facility and, if necessary, beyond the facility, including notifying his or her supervisor, the
HealthTrust ECO or the HealthTrust Ethics Line.


Controlled Substances

Some of our colleagues routinely have access to prescription drugs, controlled substances
and other medical supplies. Many of these substances are governed and monitored by specific
regulatory organizations and must be administered by physician order only. Prescription and
controlled medications and supplies must be handled properly and only by authorized individuals
to minimize risks to HealthTrust, our members, clients and patients. If a HealthTrust colleague
becomes aware of inadequate security of drugs or controlled substances or the diversion of drugs
from an organization, the incident must be reported immediately to his or her supervisor and the
local ECO and, for a consultancy engagement, to the colleague’s designated contact at the facility
and others if required by company policy.

Research, Investigations and Clinical Trials

If a HealthTrust colleague is involved in any research, investigation or clinical trial, he or she must
ensure that all internal approvals have been obtained from his or her supervisor and others as
required. We follow the highest ethical standards in full compliance with related federal and state
laws. We do not tolerate research misconduct, which includes activities such as making up or
changing results, copying results from other studies without performing the clinical investigation
or research, failing to identify and deal appropriately with investigator or institutional conflicts
of interest or proceeding without Institutional Review Board (IRB) approval. HealthTrust’s first
priority is always to protect patients and human subjects and respect their rights during research,
investigations and clinical trials.

Any HealthTrust colleague conducting a clinical trial of investigational products or services is
expected to fully inform all subjects of their rights and responsibilities of participating in the
clinical trial. All potential subjects are given a full explanation of alternative services that might
prove beneficial to them. They are also fully informed of potential discomforts and are given a full
explanation of the risks, expected benefits and alternatives. The subjects are fully informed of the
procedures to be followed, especially any that are experimental in nature. Refusal of a potential
subject to participate in a research study or the voluntary withdrawal of his or her participation in
an existing study will not compromise his or her access to services or other benefits to which he or
she is otherwise entitled. A subject’s voluntary informed consent to participate in a clinical trial is
documented and retained pursuant to Company policies.
Workplace Conduct and Employment Practices in a Healthcare Facility

Any HealthTrust colleague applying for or performing research of any type must follow all
applicable research guidelines and privacy policies and maintain the highest standards of ethics
and accuracy in any written or oral communications regarding the research project. As with all
accounting and financial recordkeeping, our policy is to submit only true, accurate and complete
costs related to research grants. Any HealthTrust colleague engaging in human subject research
must do so in conjunction with IRB approval and consistent with Company policies regarding
human subject research and IRBs.

• Discuss the situation with your supervisor
• Discuss the situation with a member of management, your Local ECO, the HealthTrust ECO, or
• Call the Ethics Line at the number below

Ethics and Compliance Officers’ Contact Information

Assistant Vice President, Ethics and Compliance
155 Franklin Road
Brentwood, Tennessee 37027
United States
Phone: +1 615-344-3947
Fax +1 866-636-6250

HealthTrust Europe
Ethics and Compliance Officer
19 George Road
B15 1NU
United Kingdom
Phone: +044 (0) 7791 511 538

Representative Office of HealthTrust
Ethics and Compliance Officer
999 Pudong Road South
Shanghai 200120
People’s Republic of China
Phone: +86 21 6058 1500

Ethics Line Phone Numbers

If calling from the United States, dial toll-free 1-800-345-7419.
• If calling from the People’s Republic of China, dial 108-11-800-345-7419. After the caller enters
the 108-11 code, a pause and/or prompted response may be required before the Ethics Line
number is entered. Dial 108-11 (wait for prompt or operator) and then dial 800-345-7419. A call
from a cell phone in P.R. China will go through only if international calling is enabled. It will be
charged as a local rather than a long-distance call.
• If calling from the U.K., dial 0800-89-0011, and then dial the Ethics Line toll-free number:


You can Acknowledgment Card by clicking code_of_conduct