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A&H Security Services, LLC 611 Jackson Bronx, NY 10455 T: (718) 292-3014 F: (718) 228-9205 CODE OF CONDUCT Introduction All A & H Secu...

A&H Security Services, LLC 611 Jackson Bronx, NY 10455 T: (718) 292-3014 F: (718) 228-9205 CODE OF CONDUCT Introduction All A & H Security personnel, including interns and volunteers, are committed to the mission of the organization to partner with our communities, lead change, promote health and prosperous individuals and families, and uphold our values of excellence, commitment, customer service, leadership. A & H and its employees must, at all times, comply with all applicable laws and regulations. A & H will not condone the activities of employees who achieve results through violation of the law or unethical business dealings. This includes but is not limited to: any payments for illegal acts, indirect contributions, rebates, and bribery. A & H do not permit any activity which fails to withstand the closest possible public scrutiny and has a zero-tolerance policy for such activity. A & H’s business practices adhere to Federal, State, and City regulations as well as the regulations set forth by licensing and credentialing bodies which sanction our delivery of services. A & H promote quality services across the network; therefore, it is expected that all conduct is well above the minimum standards required by law. All employees must ensure that their actions cannot be interpreted as being, in any way, a breach of the laws and regulations governing A & H’s operations. Any employee who has uncertainty about the application or interpretation of any legal or regulatory requirement should speak with their supervisor. If uncertainty persists, the Director/Supervisor should contact the Compliance Officer for clarification. Employee Conduct A & H expects all employees to conduct themselves in a professional and businesslike manner, each person holding themselves to the highest standards, knowing and understanding that we are all representatives of A & H. As A & H employees we are responsible for ensuring our clients’ rights and that their dignity is upheld. The use of alcohol and other drugs of abuse, gambling, fighting and other unprofessional and businesslike activities are strictly prohibited while on the job. A & H has a zero-tolerance policy for sexual and verbal (bullying) harassment and employees are expected to conduct themselves in a way which cannot be construed as such. For example, inappropriate language, posting of inappropriate materials in their work area, or inappropriate touching is not tolerated. Employees will direct any criticism of another staff member’s work or actions to that person, to that person’s supervisor, and if indicated, to Personnel. Criticism or controversy related to staff actions and/or A & H’s policies and procedures, and/or legal and regulatory bodies should never be discussed in front of clients or through the use of email, texting, and/or voicemail. Page 1 of 6  A&H Security Services, LLC 611 Jackson Bronx, NY 10455 T: (718) 292-3014 F: (718) 228-9205 A & H staff will not misrepresent his/her professional credentials, qualifications, affiliations, and functions or those of A & H colleagues. Employees who are credentialed by a regulatory body (i.e. Office of Alcoholism and Substance Abuse) or by the New York State Department of Education – Office of the Professions will adhere to the regulations outlined for their discipline, adhering to the chosen professions code of ethics/conduct in addition to the A & H Security code of conduct. This includes the individuals who are completing internships in the organization as well. Fraternization: Relationship with Staff/Clients/Patients/Residents Interactions with clients are expected to be professional and businesslike at all times. Employees are expected to maintain objectivity during all interactions. A & H maintain a zero-tolerance policy for staff that uses their positions to coerce or intimidate clients/patients for their own gain. Credentialed or licensed staff is expected to practice in accordance with recognized evidence-based practices and safeguard the welfare of the client during and after the provision of services. Any credentialed or licensed providers who have pre-existing ties to a client are expected to disclose such to their supervisor and remove themselves from the treatment of the said individual, thus ensuring that effective and ethical services can be provided. All credentialed or licensed providers are expected to refrain from frivolous self-disclosure with clients/patients. Frivolous self-disclosure refers, but is not limited, to: The provider’s current familial and personal relationships, monetary, legal, and/or health issues. The provider’s current or past struggles with alcohol and/or other drugs of abuse when not utilized as part of an evidence-based protocol. The provider’s disapproval of A & H’s policies and procedures. The provider’s disapproval of A & H personnel. Conflicts of Interest A & H maintain the expectation that all employees will perform their duties conscientiously, honestly, and in accordance with the best interests of the organization. Therefore, all employees must not use their positions or the knowledge gained as a result of their position for private and/or personal advantage. Regardless of the circumstances, if any employee realizes that a course of action they have pursued, or are presently pursuing, or are contemplating pursuing may involve a conflict of interest with A & H, the employee must immediately communicate all the facts to their supervisor. Having family or friends that work or are clients at any sites or facilities is a conflict of interest. Please inform your supervisor or Personnel if this is the case. Page 2 of 6  A&H Security Services, LLC 611 Jackson Bronx, NY 10455 T: (718) 292-3014 F: (718) 228-9205 Outside Activities and Employment At A & H, diversity is our strength. Our employees live and work in many different communities, have varied interests, and participate in a wide variety of activities in their communities, in their houses of worship, and in other civic activities. Many of these activities bring credit to A & H and are encouraged. However, employees must avoid bringing negative attention to A & H by participating in any other activity which would appear to: Create an excessive demand upon their time and attention, thus depriving A & H of their best efforts in performing their job. Create a conflict of interest – on obligation, interest, or distraction – that may interfere with the independent exercise of judgment in A & H’s best interest. Result in their arrest. Bring negative public attention to A & H. Do not solicit on site. Keep any outside activities separate from your work. Dealing with Outside People and Other Organizations: Example Politicians, lawyers, the media. All employees are expected to separate their personal beliefs and opinions from that of A & H’s mission and values. Therefore, when communicating on matters not involving A & H business, they must not use the A & H letterhead, supplies and equipment for personal or political reasons. When communicating publicly on matters which involve A & H business, employees must not presume to speak for A & H or any of its clients on any topic, unless they are certain that the views they express are those of A & H or the client, and it is the organization’s desire that such views be publicly disseminated. When dealing with anyone outside A & H, including public officials, employees must take care not to compromise the integrity or damage the reputation of either the organization, or any outside individual, business, or government body. When Law Enforcement, Emergency Responders, medical Personnel, Public Officials, Lawyers or the media arrive on a site or facility Dispatch, a staff member and a Supervisor must be informed prior to being granted access. All credential must be requested, verified and documented. Relationship with Suppliers/Vendors Employees should avoid investing in or acquiring a financial interest for their own accounts in any business which has a contractual relationship with A & H, or which provides goods or services, or both, to A & H, especially if such investment or interest could influence or create the impression of influencing their decisions in the performance of their duties on behalf of A & H. Page 3 of 6  A&H Security Services, LLC 611 Jackson Bronx, NY 10455 T: (718) 292-3014 F: (718) 228-9205 Refrain from accepting or requesting any gifts, favors or employment from vendors. Gratuities, Gifts, Entertainment, and Favors: Employees must not accept entertainment, gifts, or personal favors that could, in any way, influence or appear to influence, business decisions in favor of any person or organization with whom or with A & H has, or is likely to have, business dealings. Similarly, employees must not accept any other preferential treatment under these circumstances because their positions with A & H might be incline to, or be perceived to, place them under obligation to return the preferential treatment. Kickbacks and Secret Commissions: Regarding A & H’s business activities, employees may not receive payment or compensation of any kind, except as authorized under A & H’s business and payroll policies. A & H strictly prohibit the acceptance of kickbacks and secret commissions from suppliers or others. Any breach of this rule will result in immediate termination and prosecution to the fullest extent of the law. Organization Funds and Other Assets: Employees who have access to A & H funds in any form must follow the prescribed procedures for recording, handling, and protecting money (or vouchers) as detailed in A & H’s policies and procedures or other explanatory materials, or both. A & H impose strict standards to prevent fraud and dishonesty. If employees become aware of any evidence of fraud and dishonesty, they should immediately advise their supervisor or seek appropriate consult from the Personnel Department so that A & H can promptly investigate further. When an employee’s position requires spending A & H funds or incurring any reimbursable personal expenses, the individual must use good judgment on A & H’s behalf to ensure good value is received for each expenditure. A & H funds and all other assets of the organization are purposed for A & H’s use only and not for personal benefit. This includes the personal use of A & H’s assets, such as computers, cell phones, cars, etc. Organizational Records, Communications, Client Information and Paperwork: Accurate and reliable records, be it a medical record or financial ledger, are necessary to meet A & H’s legal and financial obligations and to manage the day to day operations of the organization. A & H’s books and records must reflect an accurate and timely manner of all business transactions. Employees responsible for accounting and recordkeeping must fully disclose and record all assets, liabilities, or both, and must use diligence in enforcing these requirements. Page 4 of 6  A&H Security Services, LLC 611 Jackson Bronx, NY 10455 T: (718) 292-3014 F: (718) 228-9205 Employees must not make or engage in any false record or communication of any kind, whether internal or external, including but not limited to: False expense, attendance, production, financial, or similar reports and statements. False advertising, deceptive marketing practices, or other misleading representations. Company and Client Paperwork cannot be removed from the site. You must have permission to remove or make a copy of any official documents with the A & H or client letterhead/logo. Privacy and Confidentiality Records kept for clinical and/or other business purposes should contain no unnecessary reference to behavior and/or social condition. Personal values and judgments are not appropriate in the records nor is the use of pejorative or disparaging language about the client/patient. It may be important to describe specific aspects of problematic behavior and in that case, it must be done in accordance with standard and recognized clinical documentation practices. When handling financial and personal information about clients/patients or others with whom we have dealings, the following principles must be observed: Collect, use, and retain only the personal information necessary for A & H’s business. Whenever possible, obtain any relevant information directly from the person concerned. Use only reputable and reliable sources to supplement this information. Retain information only for as long as necessary or as required by law. Protect the physical security of this information. Limit internal access to personal information to those with a legitimate business reason for seeking that information. Use only personal information for the purposes for which it was originally obtained. Obtain the consent of the person concerned before externally disclosing any personal information, unless legal process or contractual obligation provides otherwise. All A & H employees are bound by HIPPA laws and are expected to adhere to such, as well as confidentiality requirements of 42 CFR Part 2 (Federal confidentiality statutes covering those with substance misuse disorders), and confidentiality statues under the public health law protecting individuals with HIV/AIDS. Release of information on employees is in compliance with Local, State, and Federal laws and regulations and all requests are handled through Human Resources. Prompt Communications In all matters relevant to clients/patients, suppliers, government authorities, the public and others in A & H, all employees must make every effort to achieve complete, accurate, and timely communications. This entails Page 5 of 6  A&H Security Services, LLC 611 Jackson Bronx, NY 10455 T: (718) 292-3014 F: (718) 228-9205 responding promptly and courteously to all proper requests for information and to all complaints, prompt return of telephone calls and electronic communication, and the use of appropriate language. Replay all information in a timely manner. Page 6 of 6