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February 15, 2020

Tenet Standards of Conduct Together we’re moving health forward.

Tenet Standards
of Conduct

Together we’re moving health forward.

1

Dear Tenet colleague,

Integrity and compliance matter every day, in every situation. It is
central to everything we do as caregivers and operators. A strong
culture of compliance helps ensure that our patients receive care
that is focused on their needs, that our communities trust us to be
responsible corporate citizens, and that our shareholders and other
key constituents have confidence that we will do the right thing,
every time.

Operating our business ethically and compliantly is both a collective
obligation and an individual responsibility. Our Compliance Program
represents a shared undertaking of all colleagues, ranging from our
executives to the most junior employees. It was created to go beyond
just knowing the rules; all colleagues are expected to take ownership
of compliance and to perform all tasks with integrity.

The Standards of Conduct outlined in the following pages set the
basic principles we must follow in order to earn and maintain the trust
of our patients, communities, business partners, and shareholders. Of
course, no set of standards can adequately anticipate every situation
we might encounter at work.

When you see or hear something that doesn’t seem right, reach out
to seek help. Talk with your supervisor, your local compliance officer,
call the Ethics Action Line at 1-800-8-ETHICS, or email us at
ethics@tenethealth.com. You have the option to call or email
anonymously 24 hours a day, seven days a week. When someone
raises a good faith concern, calls the Ethics Action Line, or cooperates
with an investigation or corrective action, retaliation against that
person is strictly prohibited. By working together, we can create
an environment where we uphold the spirit and values that define
our company.

Thank you for all that you do to serve our hospitals, our patients, our
clients, and our colleagues. Compliance matters and you truly do
make a difference.

Sincerely,

Howard Hacker
Chief Compliance Officer

Contents

Letter from Howard Hacker . . . . . . . . . . . . . 1

Our Mission and Values . . . . . . . . . . . . 3

Care with Integrity . . . . . . . . . . . . . . . . . . 4
• Living Our Mission and Values
• Making the Right Decision
• See It. Say It. Fix It.
• Ethical Decisions Guide
• Commitment to Federal Programs

Care that Meets Our Standards . . . . . . . 5
• Standards Apply to All of Us
• Managers’ Responsibility
• Policies and Procedures
• Tenet s Quality, Compliance, and Ethics Program Charter
• Pre Clearance

Care with Transparency . . . . . . . . . . . . . 7
• Culture of Transparency
• No Retaliation
• Ethics Action Line
• See It. Say It. Fix It.

Care with Honesty . . . . . . . . . . . . . . . . . . 9
• Medical Records
• External Reports
• Billing
• False Claims Act
• Bribes and Kickbacks
• Government Inquiries
• Fair Competition

Care about Each Other . . . . . . . . . . . . . 11
• Care with Compassion
• Teamwork
• Privacy and Security
• Social Media and Technology
• Inappropriate Behavior
• Diversity and Inclusion
• Credentials
• Safe and Drug-Free Workplace
• Positive Workplace

Care about Limiting Gifts
and Entertainment . . . . . 13
• Gifts, Entertainment and Business Meals
• Permitted and Non-Permitted Items

Care about Conflicts . . . . . . . . . . . . . . . 16
• Avoid Conflicts
• Disclose and Withdraw
• Investing in Tenet

Care about Our Resources . . . . . . . . . . 17
• Protection of Assets and Information
• Vendors
• Communication
• Insider Trading
• Media Inquiries
• Document Retention
• Environment

Ethics and Compliance Support . . . . . . 19
• Ethics and Compliance Department
• Contact the Ethics Action Line
• Contact Other Departments for Assistance

Ethical Decisions Guide . . . . . . . . . . . . 23

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com 2

Terminology
In these Standards of Conduct, the terms “Tenet,” “the company,” “we,”
“us” or “our” refer to Tenet Healthcare Corporation and/
or its subsidiaries or affiliates. The hospitals, facilities and
programs described in these Standards are owned and/or operated by
subsidiaries or affiliates of Tenet Healthcare Corporation.

Our Mission and Values

“Quality is never an accident; it is always the result
of high intention, sincere effort, intelligent direction
and skillful execution; it represents the wise choice
of many alternatives.”

At Tenet, our business is health care. Our mission is to
improve the quality of life of every patient who enters our
doors. Our approach makes us unique and defines our future.

As we seek to improve the quality of our patients’ lives, to
serve our communities, to provide an exceptional environment
for our employees and affiliated physicians and provide an
attractive return to our shareholders, we are guided by five
core values:

• Quality. Quality is at the core of everything we do and every
decision we make.

• Integrity. We manage our business with integrity and the
highest ethical standards.

• Service. We have a culture of service that values teamwork
and focuses on the needs of others.

• Innovation. We have a culture of innovation that creates new
solutions for our patients, physicians and employees.

• Transparency. We operate with transparency by measuring
our results and sharing them with others.

These values are the reasons our patients and physicians
choose us, and we seek relationships with those who share
them.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com3

Care with Integrity

We define ourselves by our values.
In 2003, Tenet’s board of directors and CEO set a new path for
the company—one based on the values of integrity, service,
innovation and transparency. The Standards describe how
to make decisions that support these values. Because value-
based decisions are so critical, these Standards are a condition
of employment for every Tenet employee. They ensure that we
make consistent decisions that are in the best interests of our
patients, our shareholders and Tenet.

We do the right thing the first time, every time.
As Martin Luther King Jr. said, “The time is always right to do
what is right,” and each Tenet employee has an obligation to do
the right thing the first time, every time. Doing the right thing
is your responsibility and nobody has the authority to instruct
you to deviate from these Standards. Contact the Ethics Action
Line if you feel that anyone has asked you to violate these
Standards.

We see it, say it and fix it.
At Tenet, if we see a problem, we “say it” by identifying it to
others, and we fix it. Doing the right thing means standing up
for Tenet’s values even when it is not convenient. If you see
something that is wrong, say it and fix it. We must all hold each
other accountable for doing the right thing, and you have the
full support of Tenet when you do.

We get help when the right choice is not clear.
If you need help or are unclear about what to do, you have the
responsibility to get help. Use the Ethical Decisions Guide at
the back of these Standards when you are confronted with a
tough choice. You also can talk with your manager or hospital
compliance officer or contact the Ethics Action Line.

We are committed to meeting federal health care
program requirements.
Tenet hospitals treat patients who are covered by Medicare,
Medicaid, TRICARE and other federal health care programs.
Federal health care programs have many requirements that
are designed to ensure that taxpayer dollars are spent only on
care that is needed and of appropriate quality. Tenet is fully
committed to following the requirements of all federal health
care programs and failure to do so will lead to disciplinary
action up to and including termination.

Every day, Tenet employees are united by our mission to
improve the quality of our patients’ lives. This common
thread makes working for Tenet a special experience and
receiving care at our facilities different from other health
care experiences.

In order for every patient, physician and employee to
experience this difference, it is essential that every Tenet
employee uphold these Standards of Conduct.

These Standards define what it means to be a Tenet
employee, and you simply cannot work here without
committing to them.

What the Standards Mean to Me:
• My decisions support Tenet’s values.
• I am responsible for my decisions and doing the

right thing.
• I raise issues that are inconsistent with our values.
• I use the Ethical Decisions Guide when the

right decision is not clear.
• I solve problems.
• I comply with federal health care programs.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com 4

Care that Meets Our Standards

When you strive to provide excellent service, standards
are important. Standards are the lines over which we will
not cross even if it would be convenient. The Standards
of Conduct help us identify, learn and use those lines in
our daily decisions.

We Are All Required To:
• Read and certify your understanding of the Standards

within 30 days of employment and annually.
• Use the Standards in your daily decisions.
• Follow Tenet policies.
• Talk about the Standards and their application with

your supervisor or manager.
• Contact the Ethics Action Line with questions.
• Report violations.
• Participate in training on these Standards.

Additional Actions for Managers:
• Set the right ethical tone in your work areas.
• Explain how your decisions are based on our values

and these Standards.
• Answer questions and support employees who raise

good faith concerns.
• Seek guidance when the right action is unclear.

The Standards apply to all of us.
These Standards apply to every Tenet employee, as well
as the corporate board of directors, governing boards and
contractors when they are acting on behalf of Tenet. Failure
to follow or report a suspected violation of these Standards,
Tenet policies and procedures or federal health care
program requirements
will result in disciplinary action up to and including
termination. Within your first 30 days as a Tenet employee
and each year thereafter, you are required to certify that
you have read and understood these Standards. Many of
our contractors also are required to sign a certification. If
you have questions about your responsibilities, contact
your hospital or corporate compliance officer.

Managers have a special responsibility.
Tenet managers are expected to exhibit five leadership
characteristics: Character, Change, Communication,
Capacity and Collaboration. These attributes reflect
a manager’s special responsibility to set the right tone
for learning and understanding in their work areas.
It is essential that everyone reporting to our managers
understands how their work relates to Tenet’s values.
That means managers must talk about Tenet’s values
and encourage all employees to ask questions. Answering
a question with “because we’ve always done it that way”
stifles innovation and keeps us from being our best.

Managers also must set an ethical example and take
action when ethical issues are raised. They are responsible
for ensuring that their employees know these Standards
and for supporting employees who report violations in good
faith. Managers are responsible for seeking help from the
Ethics Action Line for themselves and their employees when
the right action is not clear.

We follow Tenet policies.
Health care is a heavily regulated business, and it is
important to get the details right by following our policies
and procedures. For Tenet’s policies and procedures, go
to Compliance Central on eTenet or Tenet’s public Web
site at www.tenethealth.com. The policies are organized
into eight compliance risk areas: quality; medical necessity;
qualified physicians and staff; financial incentives; licensure
and certification; patient rights; reimbursement; and
documentation, charging, coding and billing. Failure
to follow Tenet’s policies and procedures will result in
disciplinary action up to and including termination.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com5

Tenet’s Quality, Compliance and Ethics Program
Charter reflects our values.
Tenet’s Quality, Compliance and Ethics Program Charter
establishes the scope of Tenet’s ethics and compliance
program. The Charter was voluntarily adopted by Tenet
management to further Tenet’s commitment to compliance,
high ethical standards and our core values of quality, integrity,
service, innovation and transparency. The Charter requires
that every Tenet employee:

• Follow the Standards of Conduct as a condition
of employment;

• Participate in annual ethics training and specialized
compliance training tailored to our job duties.

• Work with our facility, regional, home office and
Conifer compliance teams to resolve issues of
concern; and

• Contact the Ethics Action Line if issues of concern
are not resolved timely or to our satisfaction.

The full text of the Charter is available on Compliance
Portal on eTenet and on www.tenethealth.com. Supervisors
and managers are responsible for ensuring their employees
and contractors strictly comply with the Charter.

If you feel that the right action would conflict
with these Standards, you are required to seek
pre-clearance from the Chief Compliance Officer.
If you feel that following the Standards would result in
an incorrect or unethical result, you must seek a written
pre-clearance from the Chief Compliance Officer before
proceeding. To seek pre-clearance, email the ethics and
compliance department at ethics@tenethealth.com. The Chief
Compliance Officer will consider your request and advise you
on how to proceed.

When you strive to provide excellent service, standards
are important. Standards are the lines over which we will
not cross even if it would be convenient. The Standards of
Conduct help us identify, learn and use those lines in our
daily decisions.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com 6

Care with Transparency

Transparency means being open and honest in our
communications with each other and with the public.
It means making decisions that can be scrutinized and
understood by others.

Transparency protects our most important
asset our reputation.

We Are All Required To:
• See it, say it and fix it.

Additional Actions for Managers:
• Create an environment where employees are free to

report issues without fear of retaliation.
• Support employees who report issues in good faith.
• Solve problems and get help if needed.

Transparency supports our values.
In order to improve quality of care, we must be transparent,
particularly when we make a mistake. When we identify
mistakes we can learn from them, but if we do not identify
mistakes, we miss out on lessons learned. Tenet employees
should feel comfortable raising their hands and saying “I
made a mistake,” and managers are responsible for promoting
an environment where problems are raised and—most
importantly—solved without fear of retaliation.

Tenet’s culture of transparency is supported
throughout the company.
The commitment to non-retaliation comes straight from
Tenet’s corporate board of directors and is administered by
Tenet’s Chief Compliance Officer who reports directly to the
Tenet board. When someone raises a good faith concern, calls
the Ethics Action Line or cooperates with an investigation
or corrective action, retaliation against that person is not
permitted. Tenet takes reports of retaliation very seriously. If
you feel that you have experienced retaliation, immediately
report it to the appropriate manager who is not involved
in the issue or contact the Ethics Action Line. Any time
there is an allegation of retaliation, the allegation will be
investigated and appropriate steps will be taken to protect
those who report retaliation.

The Ethics Action Line works.
If you contact the Ethics Action Line, your call will be answered
by an ethics advisor 24 hours a day, seven days a week. After
hours and on weekends, the Ethics Action Line is answered by
a third party engaged by Tenet to provide additional coverage.
The ethics advisor will ask you specific questions to better
understand your concerns.

When reporting, it is important for you to have as many facts
as possible so the ethics advisor can give the most appropriate
advice to you and/or report the information to the appropriate
individuals for investigation and resolution. Callers may call
back and check on the status of the investigation. To protect
your confidentiality and privacy, we do not disclose the details
of the investigation or any disciplinary action. However, the
Ethics Action Line will inform you whether the investigation is
complete and if the issues were addressed.

Example of Tenet’s No Retaliation Policy
If a circulating nurse in the operating room reports that a surgeon is
not participating in the time out performed to confirm the
right patient, right procedure and right side/site, an investigation
will be conducted. If there is any attempt to remove the nurse from
the schedule, discipline or terminate the nurse because the nurse raised
a good faith concern about quality, the compliance officer,
human resources representative and leadership will stop the retaliation
and take the appropriate steps.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com7

The Ethics Action Line is independent
and anonymous.
The ethics advisors who answer the Ethics Action Line
report to our Chief Compliance Officer who reports
directly to the Tenet board. The Ethics Action Line does
not have access to caller ID and thus you can make your
call anonymously if you wish. When you call, we need
enough details to investigate your concerns including the
department, facility and, in some limited circumstances,
your name. If the caller discloses his or her name but
requests confidentiality, the Ethics Action Line will keep this
information confidential to the extent permitted by law.

All reports of an ethical violation
must be made in good faith.
Do not make an ethics report if you do not believe in good
faith that the Standards of Conduct have been violated. Do
not twist or make up facts to get someone else in trouble.
Appropriate disciplinary action will be taken if information
has not been provided in good faith.

See it. Say it. Fix it.

See it…
• Speak up if you see or think you see something

that violates these Standards. You cannot look
the other way.

Say it…
• to your coworkers. You should feel comfortable

speaking up to your coworkers. Sometimes, all
we need is a simple reminder.

• to your manager. If you do not feel comfortable talking
to your coworkers, turn to your manager. Managers are
responsible for creating a workplace where employees
are comfortable raising issues without fear of
retaliation. If your manager asks you to do something
inappropriate or something that would violate these
Standards, go “one over” your manager or call the
Ethics Action Line. Your concerns will be investigated,
and retaliation will
not be tolerated.

• to your human resources representative. Issues
involving employment matters should be taken to
human resources.

• to your hospital compliance officer. Your hospital
compliance officer is available to answer your
questions and discuss your concerns. Your regional
compliance director and Tenet’s chief compliance
officer are also available to assist you if you want
to speak to someone outside your facility.

• to the Ethics Action Line. If you do not feel that you
can address your concern at the local level, call the
Ethics Action Line at 1-800-8ETHICS or email ethics@
tenethealth.com. The Ethics Action Line
is available to guide you and answer your questions
or to report a concern.

Fix it…
• When you see and say an issue, do not forget to help

fix it. Many issues can and should be corrected on the
spot. In some cases, the solution may require action
by your manager or others, and everyone is required to
help resolve any concerns.

What about accounting concerns?
You are required to contact the Ethics Action Line if you see or think
you see accounting improprieties or have concerns about
Tenet s internal financial controls or audits. The Ethics Action Line
reports concerns to the audit committee of the Tenet board of
directors. You also may report directly to the attention of the audit
committee at the address listed in the Support section on
page 19.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com 8

Care with Honesty

Our word is our bond, and we do not take that lightly.
Our U.S. health care system is one of the largest and
most complex honor systems in the world. It depends
on providers like us to do the right thing by honestly
performing and billing for their services.

We recognize that the law is a minimum standard of
behavior—not a maximum—and we follow the spirit of
the law. It is a good business practice to ensure that our
behavior is not so close to the line that someone else
might question whether it is lawful.

We Are All Required To:
• Tell someone if you see an error or something false

and fix it.
• Not sign your name unless you know the statement is

true.
• Not sign other people’s names or share passwords.
• Raise possible dishonesty with your manager, hospital

compliance officer or the Ethics Action Line.
• Compete fairly.

We are honest in what we write, say and do.
When we make a statement or sign our names to any
document, we are confirming that the statement is true.
We do not back-date documents, make up entries or make it
appear as though we documented something that we did not.
We do not sign other people’s names to documents, and we
do not share each other’s passwords.

Our patients depend on us and their physicians to accurately
document their medical records. We make every effort to
ensure that medical record entries are clear and complete
and reflect exactly the care that was provided to a patient.
We do not exaggerate or lead others to document in a certain
way. If we add to a record, we note the addition as a late
entry in accordance with hospital policy.

We ensure that all external reports are filed on time and are
complete, accurate and understandable. These include cost
reports, Securities and Exchange Commission reports, tax
reports, plans of correction and reports to private accrediting
bodies like the Joint Commission. When we say we will do
something, we follow up to make sure it is done. Our financial
records conform to generally accepted accounting principles,
and we never attempt to hide expenditures, funds, assets or
liabilities.

We are honest in our bills for services.
We make every effort to submit accurate and truthful bills for
our services, and we bill only for services that were actually
provided, properly documented and coded. We ensure that
our bills meet federal health care program requirements,
and we do not submit bills that are exaggerated, fictitious or
upcoded. If personal knowledge is required to fill out a form,
we fill it out only if we have that personal knowledge. If we
see a billing error, we involve a manager, compliance officer
or the Ethics Action Line. We investigate and correct the
error prior to submitting the bill. If we have already billed,
we correct the underlying problem and make appropriate
refunds. If we are not sure how to correct the error, we report
it to a manager, the compliance officer or the Ethics Action Line.

The Federal False Claims Act and Deficit Reduction Act protect
government programs including Medicare, Medicaid and
TRICARE from fraud and abuse. Tenet complies with these
and all laws and has policies to detect, report and prevent
waste, fraud and abuse, as well as provide protection for
whistleblowers. For additional information, please refer to
www.tenethealth.com.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com9

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com 10

If you see a false claim or report, fix it before
it is submitted.
If it has already been submitted, contact your manager,
hospital compliance officer or the Ethics Action Line.
Failure to do so will lead to disciplinary action up to and
including termination.

We prohibit financial incentives to provide care.
We never offer, give or receive something of value in hopes
of inducing referrals or as a reward for referrals from other
businesses. The “something of value” does not have to just
be money. It can also be services, gifts, entertainment or
anything else that has value to the recipient. We never offer,
accept or give bribes or kickbacks. We never compensate
anyone based on referrals. If you believe that someone
has offered or received a bribe or kickback, or provided
something of value in exchange for referrals, contact the
Ethics Action Line. See the section “Care about Limiting
Gifts and Entertainment” for additional requirements.

We respond to government inquiries.
As a good corporate citizen, Tenet cooperates with
government inquiries. At the same time, we consult with the
law department and our compliance officer before responding
to any non-routine requests to make sure that contacts with
government entities are handled properly. We are always clear
and truthful in what we say to those who make inquiries. We
never alter or destroy records if we are aware of an existing or
potential government inquiry.

We compete fairly.
Being innovative means that we do not need to compete
against others unfairly. We do not seek to gain an edge
through unfair competition. We comply with all antitrust
laws and never make agreements with competitors that
create monopolies or stifle competition. We do not illegally
obtain or use proprietary information from competitors, nor
do we use deceptive means to gain such information.

Care about Each Other

We all learned the golden rule as children, and it still
applies today. We treat each other as we want to be
treated. It is as simple as that.

We Are All Required To:
• Treat each other the way that we want to be treated.

Additional Actions for Managers:
• Create an environment in which we can honor and

respect each other.

We provide care with compassion.
We treat all our patients equally and with compassion, dignity
and respect. We never distinguish among patients based on
race, ethnicity, religion, gender, sexual orientation, gender
identity or expression, national origin, age, disability, veteran
status or other characteristics protected by law.
We involve our patients in decisions affecting their care,
and we disclose unanticipated outcomes to patients and
their families. We obtain their consent for treatment or
participation in research, and we confirm that all available
options are explained. We review the medical procedures
conducted in our facilities to confirm they are medically
necessary according to good medical practices, and we seek
reimbursement based on the rules of our payors.

We value teamwork.
Health care is a service industry, and teamwork and
collaboration are essential to providing excellent service and
solving problems—no matter how big or small. We work
together to achieve the common goal of serving our patients.

We protect the right to privacy.
Our patients trust that we will protect the information
provided to us including their health information and
personal data like social security numbers. We release
information to vendors or others only in accordance with
proper procedures. We take steps to prevent identity theft
by protecting social security numbers and other personal
data, and securing our systems from unauthorized access.
We access health and personal information and share it with
coworkers only when authorized to do so and for the purpose
of doing our jobs. Sometimes our coworkers become our
patients, and when this occurs, we afford our coworkers the
same privacy rights as every other patient.

We are responsible with Social Media and
Technology.
We never post patient information or photographs to a Web
site, social media page or public forum – even if the patient
is not identified. We do not use our personal devices to
text patient healthcare information for any reason unless
otherwise allowed by Tenet policy. We do not take or
transmit photographs of patients except as required for
patient care and within the requirements of our policies.

What if I have a dispute with my manager?
Your human resources representative will help with employment matters
involving personality disputes, diversity and the workplace.
Your compliance officer and the Ethics Action Line are available to
assist if you have ethics and compliance concerns.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com11

We have positive physician relationships.
We treat our affiliated physicians with respect, and they have the obligation to treat us with respect.
We report inappropriate behavior by physicians and vice versa. A human resources representative will
investigate inappropriate behavior by a Tenet employee, and the appropriate medical staff committee
will investigate inappropriate behavior by a physician. If you are aware of any behavioral issues, contact
your compliance officer or the Ethics Action Line.

We are committed to diversity and inclusion.
At Tenet, we believe in a diverse and inclusive environment, one that is grounded in our dedication to
the health and well-being of all people. Respecting, nurturing, and encouraging diversity of thought,
background, and experience contribute to positive work environments that result in exceptional patient
care. We support Tenet’s equal opportunity employment and employee development programs that
embrace the unique characteristics of our people and our communities and that encourage continuous
individual improvement. We embrace the diversity of our coworkers, physicians, vendors and patients.
We never harass or discriminate on the basis of race, ethnicity, religion, gender, sexual orientation,
gender identity or expression, national origin, age, disability, veteran status or any other characteristics
protected by law. We embrace diversity because it is our culture, and it is the right thing to do. We are
also committed to providing reasonable accommodations to employees who have qualified physical or
mental disabilities.

Our credentials matter.
Credentials communicate to our patients and physicians that we are qualified to do our jobs. That’s
why we are committed to maintaining all required credentials, licenses and certifications. We do not
hire, contract with or bill for services rendered by persons or entities who are excluded or are pending
exclusion from participating in the federal health care programs by the Office of Inspector General or
Government Services Administration. We do not allow caregivers with lapsed or revoked credentials to
provide care to patients.

We have a safe and drug-free workplace.
The health and safety of our patients is our primary concern. We follow health and safety policies
and regulations that apply to our work and the guidance provided by the facility’s safety officer. This
includes following procedures for handling and disposing of hazardous materials. We access and handle
prescription drugs, controlled substances and other medical supplies only as authorized and administer
them only by physician order. We may not be under the influence of alcohol or illegal drugs on company
property or during work time. Employees are required to report any unsafe situations to their facility
safety officer.

We have a positive work environment.
We do not tolerate conduct that disrupts our work environment including behavior that is disrespectful,
hostile, violent, intimidating, threatening or harassing.

Harassment can be particularly harmful to the work environment, thus we have a special responsibility
to report any instances of it that we may see or know about. Requests for sexual favors, sexual advances
and other unwelcome verbal or physical conduct of a sexual nature are violations of our values and
policies. We speak up if a coworker’s conduct makes us feel uncomfortable.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com 12

Care about Limiting Gifts and Entertainment

The best “thank you” any vendor can give us is to provide
excellent service at a reasonable price.

We do not want anyone to have the impression that we
are using our position at Tenet for personal gain or that
we cannot be objective.

Our decisions should be based solely on what is best for
Tenet and the patients we serve.

We Are All Required To:
• Learn our Standards on gifts and entertainment.
• Communicate our Standards to others.
• Return items or seek advice if gifts or entertainment

do not meet these Standards.

Additional Actions for Managers:
• Set an example by knowing and implementing the

gift and entertainment policy in your work areas.

We do not let perks cloud our decisions.
All gifts, entertainment and business meals provided or
received must be reasonable and small enough that they
do not influence our decisions. We never offer or accept
anything of value in exchange for referrals or other business.

We communicate to vendors, physicians, patients, customers
and others that our values restrict what we can give
and receive because we want our services and business
relationships to stand on their own. We do recognize that
certain items are appropriate and do not present a risk of
influencing our decisions. Each Tenet employee needs to be
sure that even permitted items do not damage our reputation
or integrity under the circumstances. If you are unsure,
contact your hospital compliance officer or the Ethics Action
Line before offering or receiving such items.

What constitutes a gift?
A gift is any item of value – including everything ranging from
marketing items like t-shirts, flowers and gift baskets –
if the recipient is not expected to pay for the item.

What constitutes entertainment?
Entertainment is attendance at any event such as a sporting
event, concert or play where the recipient is not expected to
pay for the entrance fee or ticket.

What constitutes a business meal?
A business meal is any meal where the purpose of the meal
is to discuss Tenet business.

What if I receive something that is not permitted?
If an item is not permitted by these Standards, it should be
returned with an explanatory note. The only items that do
not need to be returned are perishable items such as food
or flowers. Perishable items may be donated to a charity or
shared in the work area. If returning the gift would create an
awkward situation, please call the Ethics Action Line.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com13

Permitted Gifts and Entertainment.
The following items are permitted but they must be
reasonable and appropriate under the circumstances and all
requirements of Tenet policy must be met:

Occasional gifts:

• Purchased or reimbursed by Tenet for a Tenet employee.
Example: A manager may provide a gift card to a coffee store
to an employee. Note: Gifts provided by Tenet to employees
are the employee’s taxable income. Contact
the payroll department for guidance. For purposes of
the Standards of Conduct, Conifer employees are Tenet
employees.

• Purchased personally by a Tenet employee for a Tenet
employee.
Example: A manager may personally purchase a gift card to
a book store for an employee. However, the manager should
disclose that the gift is from him or her personally to avoid
confusion with our Standards.

• Purchased by Tenet for a patient with a retail value that does
not exceed $10 per item and $50 in total per year
per family and is not cash or its equivalent. Contact your
compliance officer before proceeding.
Examples: A hospital may provide a $10 t-shirt to the parents
of a newborn. A hospital may provide a $10 gift certificate to
a restaurant to a patient who had to wait too long for his
meal.

• Purchased by Tenet for a vendor or customer, or received
from a vendor or customer, with a retail value that does
not exceed $50 per item per employee and $100 in total per
year and is not cash or its equivalent. For purposes of the
Standards of Conduct, EMS providers and contracted
employees are considered vendors. This includes, but may
not be limited to, employees who work for Dell, dietary
services vendors, housekeeping vendors, HealthTrust, etc.
Examples: An accounting firm may purchase a $50 clock
or a retiring Tenet employee. A vendor may provide a $100
fruit basket to the radiology department if the basket is
shared among employees.

• Purchased by Tenet for a physician in limited circumstances
as long as the value of the item is within the non-monetary
compensation limit, and the item is not cash or its equivalent.
Contact your compliance officer before proceeding. Example: A
hospital may buy gift baskets valued at $100 for each member of
its medical staff to celebrate Doctors’ Day. The hospital must log
the value on each physician’s non-monetary compensation log
without exceeding the limit.

• Received by a Tenet employee from a physician as
long as the amount does not exceed $50 per item per
employee and $100 in total per year, and the item is not
cash or its equivalent.
Example: A physician may provide each nurse on the
unit a$50 gift certificate redeemable to purchase a
holiday turkey

Occasional business meals:

• Purchased by Tenet for a Tenet employee.
Example: A lab manager may take his staff to lunch to
celebrate the completion of a project.

• Purchased by Tenet for a vendor or customer or
received from a vendor or customer.
Example: A computer hardware vendor may take the
information services director to lunch to discuss the
performance of the hardware.

• Purchased by Tenet for a physician, or received from
a physician, in limited circumstances. Contact your
hospital compliance officer before proceeding.
Example: A chief nursing officer may take the physician
who serves as medical director of the
ICU to lunch to discuss infection control rates.
The physician’s medical directorship agreement must
state that the physician will attend meals from time to
time to discuss the physician’s duties.

Occasional business entertainment:

• Purchased by Tenet for a Tenet employee.
Example: The hospital may host an employee picnic.

• Purchased by Tenet for a vendor or customer, or
received from a vendor or customer, as long as
the cost paid per employee does not exceed $100 per
vendor or customer in total per year, and the vendor
or customer attends the event with the employee to
discuss business.
Example: A vendor may take a quality manager to a
museum event with a ticket price of $50.

• Purchased by Tenet for a physician or received from
a physician in limited circumstances. Contact your
hospital compliance officer before proceeding.
Example: The hospital may host an annual physician
appreciation dinner that meets the requirements of the
law department policy.

What about gift cards?
We permit gift cards as long as they are not redeemable for cash or free
health care items or services. For example, we permit a gift
card to a book store, a restaurant or a grocery store. The only time we
can provide a gift card redeemable for cash is to an employee.
All gifts and gift cards provided to employees are reportable as income.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com 14

Gifts and Entertainment that are not permitted
• Gifts received from patients. We may not accept or

solicit gifts from patients in any form. Contact the Tenet
government relations department before interacting with
government officials.
Example: A patient may not tip a nurse.

• Gifts received from or purchased for government officials.
We may not accept or solicit gifts from government officials.
This includes foreign government officials and their agents.
Contact the Tenet government relations department or the
law department before interacting with any government
officials.

• Free health care items or services of any value purchased for
or provided to patients, physicians or government officials,
unless specifically permitted by Tenet policy.
Examples: A hospital may not provide a certificate for
free non-preventive health care services to a Medicare
beneficiary. However, a hospital may donate a free
mammogram to a charity.

• Business meals purchased for or received from government
officials or patients. Congress passed new rules regarding
government officials and representatives. Contact the
government relations department before interacting with
government officials.
Example: A hospital may not provide lunch to a member
of Congress visiting the hospital.

• Entertainment purchased for or received from government
officials or patients.
Example: A patient may not give an employee tickets to
a concert as a thank you.

• Trips purchased for or received from a vendor, customer,
patients, government officials or physicians. Tenet employees
are required to follow Tenet’s travel policy, and Tenet
shall pay for all business trips taken by Tenet employees.
Examples: A vendor may not take an employee to the Super
Bowl to discuss business. A vendor may not pay for a trip for
an employee to visit the vendor and evaluate its products.

• Cash, traveler’s checks, money orders, stock, negotiable
instruments, honorariums or other cash equivalents provided
to or received from patients, vendors, customers, physicians
or government officials.
Example: A hospital may not provide a $50 American Express
gift card to a physician.

• Items solicited by the recipient, prohibited by the recipient’s
policies or that would violate the law.
Example: A hospital may not provide tickets to a concert to a
physician who requests them.

• Items provided to or received from anyone being considered
during a pending purchasing decision.
Example: A vendor may not provide a bottle of wine to the
materials manager who is considering buying supplies from
the vendor.

Other examples of items that are not
permitted:
• An OB unit may not provide a $100 blanket as a gift to a new

mom because it exceeds the $10 limit.

• A vendor may not provide a $100 bottle of wine to an
employee because it exceeds the $50 limit.

• The CEO may not take the medical director to dinner every
week to discuss his duties because this is not occasional and
therefore not reasonable.

• Tenet will not pay for a department manager to take his
employees to lunch every week to discuss their work. This is
not reasonable.

• A hospital may not provide a $25 gift certificate to a patient.
This exceeds the $10 limit.

• A vendor may not sponsor a hospital event or an open house
for a Tenet facility. This would likely exceed the $50 limit and
may create a real or perceived conflict of interest.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com15

Care about Conflicts

We avoid conflicts of interest.
In our work, we have a duty to put the interests of Tenet before
our own. We avoid conflicts of interest where someone might
question whether we are acting for Tenet’s benefit or for
personal gain. Managers and those who work regularly with
vendors are required to annually report any actual or potential
conflicts of interest by completing the Conflict of Interest
Disclosure form, found on eTenet. In addition, any time a
potential conflict arises, we are required to update our annual
Conflict of Interest Disclosure by completing a new form and
seeking guidance from the ethics and compliance department
before proceeding. If you have questions about whether a
situation presents a conflict, contact the Ethics Action Line.

We disclose and withdraw when conflicts arise.
If we are ever in a situation where someone might question
our loyalty to Tenet or there is the appearance of a conflict,
we disclose it and withdraw ourselves from making a decision
when we have a conflict. We disclose it to Tenet by completing
a Conflict of Interest Disclosure form, and we disclose it to
others involved in the situation. We then withdraw from
the selection of a vendor by letting someone else make the
selection.

For example, perhaps you are tasked with buying the linens
at your hospital. Your best friend from college happens
to sell linens. Even if your friend offers the best deal, the
appearance of a conflict triggers the requirement to disclose
the relationship to your manager and complete a Conflict
of Interest Disclosure form. In this situation, the ethics and
compliance department would advise that the hospital should
obtain three bids for the service and that someone other than
you should make the purchasing decision. That way, someone
who does not have the appearance of a conflict is the decision
maker.

Failure to disclose and withdraw from conflicts of interest can
result in disciplinary action up to and including termination.

We avoid conflicts when investing in Tenet.
Investing in Tenet securities provides an opportunity to share
in the future growth of the company, but we do not engage
in short-term speculation based on fluctuations in the market.
These activities may put your personal gain in conflict with
the best interests of Tenet and our shareholders. We do not
trade in options, warrants, puts and calls or similar derivative
instruments on Tenet securities. Contact the law department
for additional guidance.

To avoid a question about our integrity, we must be able
to identify and disclose potential conflicts, disclose them
and withdraw ourselves from making decisions where it
may appear that we are not being objective.

We Are All Required To:
• Identify situations where it could appear to an outsider

that your personal interests conflict with Tenet’s
interests.

• Disclose the situation to your manager and complete a
Conflict of Interest Disclosure form.

• Withdraw yourself from making decisions that
have the appearance of a conflict.

Examples of Potential Conflicts:
• Employment with an entity that competes, contracts

with or is a supplier of Tenet.

• A financial or ownership interest in an entity that
competes with Tenet.

• Using Tenet property, information or position for
personal gain.

• Taking for ourselves opportunities discovered through
our jobs.

• Outside jobs or positions that conflict with our work at
Tenet.

• Purchase for Tenet from someone you purchase from
personally or vice versa.

• Buying from or making any business decision that
involves friends or family.

• A supervisory or reporting relationship to family or
those with whom we are personally involved.

You scratch my back, and I scratch yours?
If you buy a boat from your neighbor who owns a health care consulting
business, you have a financial relationship with your
neighbor. You would need to disclose this financial relationship if your
facility considers contracting with his company. You also
would need to ensure that you are not involved in the bid selection
process involving your neighbor. The appearance of a quid pro
quo relationship is inappropriate and may raise concerns under the Anti
Kickback statute.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com 16

Care about Our Resources

Resources permit us to care for patients and operate our
business. We eliminate wasteful spending, fraud and
other concerns that deplete our resources. We ensure
that our resources are used to support Tenet’s mission
and are utilized in ways that support our values and the
interests of our shareholders.

We Are All Required To:
• Protect Tenet assets and proprietary information.

• Communicate efficiently and effectively.

• Not trade on inside information.

• Refer media requests to the Communications Center.

• Retain documents as required.

We protect assets and information.
We have an obligation to our shareholders to use our
resources responsibly and only for Tenet’s business purposes.
We spend Tenet funds wisely and eliminate waste. We use
Tenet’s physical assets like computers, vehicles, machinery
and work space for Tenet’s business, and we protect these
assets from loss, damage and theft. We don’t waste supplies,
equipment, space, capital or time. We also protect Tenet’s
non-physical assets like strategic plans, plans for acquisitions
and divestitures, non-public financial information, trademarks,
processes, know-how and other proprietary information. We
keep information confidential and disclose it only to those
who are authorized to know. We take precautions by avoiding
discussions of sensitive matters over cell phones, password
protecting computers and documents, and performing virus
checks before downloading a file or installing a program.

We expect our vendors to follow these Standards.
Vendors, suppliers, contractors, consultants, business partners
and others with whom we do business are vital to our success.
We expect them to adhere to these Standards and to always
treat us with the same respect, fairness and professionalism
that we demonstrate to them. If we entrust them with
confidential information, we expect them to uphold that trust.
We are careful about who we partner with. We look into the
background of our vendors and confirm that they are not
excluded from federal program participation before working
with them. We pay only reasonable fees for services and we
never engage consultants who make unrealistic promises. Our
payments to vendors do not incentivize them to recommend
practices that lead to excessive utilization or reimbursement.
We do not allow others to use the Tenet name to advertise
their products or promote their interests above the interests of
Tenet or our patients. We will terminate our arrangements with
vendors who do not follow our Standards of Conduct when
working for Tenet.

We communicate wisely.
We always communicate in an open, honest and respectful
way, refraining from communications that are unprofessional
or would be embarrassing if made public. It is generally
acceptable to use telephones, email and the internet at work
for personal purposes, but a manager or supervisor must
approve, and the use must be appropriate (nothing offensive or
inappropriate) and limited, taking up only a small part
of work time without additional cost to Tenet. We also must
remember that the company has an obligation to monitor
email and internet use, sometimes without notice.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com17

We communicate effectively.
What we say and how we say it ultimately reflects on
Tenet. That’s why we ensure that all written and verbal
communications – even emails – reflect the highest
professional standards. We send messages only to those
who need them, and we clearly state the purpose of the
communication and what we seek in response. We think about
the size and content of our emails to avoid wasting company
resources with excessive distribution or attachments. We do
not use aggressive language or tone in our communications
and never write anything we would not want to read in the
newspaper.

We do not trade on inside information.
Inside information is information that is important enough
to potentially affect a company’s stock price but that is not
yet public. Some examples of inside information are financial
results, earning projections, changes in senior management,
information about acquisitions, etc. If we have access to inside
information about Tenet or one of our business partners, we
may not trade in that company’s stock until the information
is made public. Nor may we “tip” others to do so. Trading
on such information, or “tipping” others, is known as insider
trading and is a violation of federal law. Contact the law
department for additional guidance and restrictions.

We refer the media to Corporate
Communications.
In order to avoid confusion, Tenet communicates with the
community in a clear, unified voice. Any media inquiries or
requests to issue press releases or use our company logo
should be referred to Corporate Communications at 469-893-
2640.

We retain documents as required.
We retain documents, email and other communications for
the appropriate and legally required length of time described
in Tenet’s document retention policy. We never destroy
documents before the permitted destruction date or if Tenet’s
law department has requested we retain them.

We care about our planet.
We reduce our consumption of natural resources and our
impact on the environment. We have an active recycling
program and work to reduce our carbon footprint. We
use electronic medical records that improve patient care
and reduce waste. We ensure that we properly dispose of
hazardous materials and that we maintain all certifications
required to use such materials. We are proud to publish
an annual sustainability report that describes Tenet’s
sustainability efforts – its environmental, social and economic
footprint.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com 18

Ethics and Compliance Support

Tenet’s Ethics and Compliance Department
Tenet has instituted some of the most rigorous standards for
corporate governance, ethics and compliance – not just in our
industry, but in all of corporate America.

Tenet’s ethics and compliance program promotes open
identification, discussion, reporting and resolution of ethics and
compliance issues without fear of retaliation. We also openly
communicate with the Office of Inspector General of the U.S.
Department of Health and Human Services, pursuant to Tenet’s
Corporate Integrity Agreement, as well as communication with
other state and federal regulators.

The ethics and compliance department is led by
Audrey Andrews, Tenet’s chief compliance officer. Each
of Tenet’s hospitals has a dedicated hospital compliance officer
who reports through a regional compliance director to the
chief compliance officer.

For more information about Tenet’s ethics and compliance
program, visit Compliance Central on eTenet or Tenet’s public
Web site at www.tenethealth.com.

Contact Us

Tenet Ethics Action Line
The Ethics Action Line is available 24 hours a day, 365 days a
year. Callers to the Ethics Action Line may remain anonymous,
and those who choose to give their names will have their
identity protected to the extent allowed by law.

The Ethics Action Line can be reached in several ways:
Phone: 1-800-8ETHICS
Fax: 1-469-893-6341
Email: ethics@tenethealth.com

1445 Ross Avenue
Dallas, Texas 75202

Other Resources

• Quality, Compliance and Ethics Committee
of Tenet’s Board of Directors: 1-800-8ETHICS

• Audit Committee of the Board of Directors
(for reports about accounting, internal
controls and/or auditing): 1-800-8ETHICS

• Ethics and Compliance Department: 469-893-6147

• Audit Services Department: 469-893-6915

• Human Resources Department: 469-893-2668

• Communications Center: 469-893-2640

• Quality Management Hotline: 469-893-6767

• Government Relations Department: 469-893-2413

• Coding Compliance: 469-893-6780

• Patient Privacy and Security: 469-893-2009

• Billing Compliance: 469-893-2022

• Policies and Procedures: 469-893-6244

• Training and Education: 469-893-6748

• Law Department: 469-893-2442

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com19

Notes

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com 20

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com21

Notes

Special thanks to Professor Marianne Jennings of the W.P. Carey School of Business at Arizona State
University for her ethics training program that inspired many of the ideas in these Standards.

The quote about quality on page 3 has been attributed to many sources.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com 22

Ethical Decisions Guide

Use this tool to assist you in making ethical decisions consistent with Tenet’s values:

Does it comply with
these Standards?

NoDo not
proceed

I Don’t Know Contact your manager, hospital compliance officer,
human resources representative or the Ethics Action
Line before proceeding.

Yes

Does it comply with
Tenet policy?

NoDo not
proceed

I Don’t Know Contact your manager, hospital compliance officer,
human resources representative or the Ethics Action
Line before proceeding.

Yes

Is it legal?
NoDo not

proceed
I Don’t Know

Contact the Tenet law department before proceeding.

Yes

Could it harm
patients?

YesDo not
proceed

I Don’t Know Contact your manager or clinical experts in your facility,
the Tenet clinical quality department or the Ethics
Action Line before proceeding.

No

Could it harm
Tenet’s employees,

physicians,
regulators or

shareholders?

YesDo not
proceed

I Don’t Know
Tenet has many constituents including employees,
physicians, government regulators and shareholders.
All of their interests need to be balanced when making
a good decision. Contact the resources listed in these
Standards before proceeding.

No

Could it adversely
impact Tenet if

everyone did this?

YesDo not
proceed

I Don’t Know

At a company of our size, consider if every employee
or facility took the same steps you are considering. If
doing something on a larger scale would make you or
your manager uncomfortable, you should not proceed.
Discuss these issues with your manager and any of the
resources listed in these Standards before proceeding.

No

Would I feel
comfortable reading

about this in the
newspaper?

NoDo not
proceed

I Don’t Know
We should feel comfortable if others read about our
decisions in the newspaper. Contact your manager,
hospital compliance officer, Communications Center,
Tenet law or government relations departments, or the
Ethics Action Line before proceeding.

Yes

Proceed with the decision.

Contact the Ethics Action Line at 1-800-8ETHICS or ethics@tenethealth.com 23

 

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