Ethical Behavior

    St. Jude Vendors Code of Conduct Policies



    Purpose

    This policy sets forth the standards of conduct and professional integrity that are the hallmark of St. Jude Children’s Research Hospital. High ethical standards are necessary to maintain St. Jude’s tradition of excellence and the pride and confidence of our employees, patients and donors. As one of the world’s premier centers for research and treatment of catastrophic diseases in children and supported primarily by funds from volunteer contributions, the hospital has a special responsibility to its patients and donors.

    St. Jude expects every employee to adhere to high ethical standards and to promote ethical behavior. Every employee’s action should be judged considering whether that action is right, fair and legal, and whether that action could withstand the scrutiny of outsiders.


    Applicability

    This policy applies to all persons who represent the hospital, including board members, executive officers, employees, faculty, contract providers, vendors and volunteers. Certain of these individuals are subject to professional ethical requirements in addition to the requirements of this ethics policy. St. Jude expects for there to be few, if any, conflicts between those dual sources of ethical obligations for these individuals. In the rare circumstances when conflicts do exist, each affected individual must honor his or her professional duties as imposed by applicable law and professional ethics codes. Only if permissible while adhering to these professional duties, such individuals are encouraged to consult with St. Jude prior to making an act or omission required by their professional ethical obligations which would not otherwise be permissible under this ethics policy.


    Patient Care and Other Ethical Standards

    It is the policy of St. Jude to engage in and encourage ethical behavior in all aspects of our operation. All employees shall:

    Marketing efforts shall not mislead the public or misrepresent the facility as to the types or quality of services available. Should the patient require or request services not available or inconsistent with the facility's mission, transfer to a facility prepared to fulfill this need will be offered.

    All tasks performed by a patient or a patient’s family on behalf of the hospital or ALSAC are done voluntarily and are in no way required or expected as a part of receiving care at St. Jude.

    St. Jude provides care regardless of the family’s ability to pay.


    Financial Reports and Internal Controls

    St. Jude’s policy is to provide full, fair, accurate, timely and understandable disclosure in its financial reports and its other public communications. St. Jude’s executive and financial officers must ensure that they and other employees at St. Jude comply with the hospital’s disclosure controls and procedures and internal controls for financial reporting.

    All financial information must reflect actual transactions and conform to generally accepted accounting principles. All funds or assets must be properly recorded in the books and records of the hospital. St. Jude maintains a system of internal controls to provide reasonable assurances that all transactions are executed in accordance with management’s authorization and are recorded in a proper manner so as to maintain accountability of St. Jude’s assets.


    Accuracy, Retention, and Disposal of Documents and Records

    Each St. Jude employee 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 records are available to support our research practices and other actions. No one may alter or falsify information on any record or document. Records must never be destroyed in an effort to deny governmental authorities that which may be relevant to a government investigation.

    Medical and business documents and records are retained in accordance with the law and St. Jude’s document retention policies. Medical and business documents include paper documents such as letters and memos, computerbased information such as email or computer files on disk or tape or any other medium that contains information about the organization or its business activities. St. Jude employees must not tamper with records. Finally, under no circumstances may a St. Jude employee use patient, colleague or any other individual’s or entity’s information to personally benefit.


    Violations of the Policy

    Part of every employee’s job and ethical responsibility is to help enforce this policy and the other policies and procedures of the hospital. All employees should be alert to possible violations and report possible violations to their manager, supervisor, or through the EthicsPoint hotline, which may be accessed through the St. Jude intranet site. All employees must cooperate in any internal or external investigations of possible violations. Reprisal, threats, retribution or retaliation against any person who has in good faith reported a violation or a suspected violation of law, this policy and the other policies and procedures of the hospital, or against any person who is assisting in any investigation or process with respect to such a violation, is prohibited.

    St. Jude will take appropriate action against any employee whose actions are found to violate this policy and the other policies and procedures of the hospital. Disciplinary actions may include immediate termination of employment at St. Jude’s sole discretion. Where St. Jude has suffered a loss, it may pursue its remedies against the individuals or entities responsible. Where laws have been violated, St. Jude will cooperate fully with the appropriate authorities.


    Availability of Ethics Policy