Change Healthcare Supplier Code of Conduct

Change Healthcare is committed to the highest standards of social and environmental responsibility and ethical conduct. These standards apply to all Change Healthcare employees, directors, and officers. Similarly, Change Healthcare expects its suppliers to embrace this commitment to integrity by complying with and training its employees on the Change Healthcare Supplier Code of Conduct.

The Change Healthcare Supplier Code of Conduct outlines the expectations Change Healthcare has of its Suppliers. A "Supplier" is any business, company or other entity that provides, or seeks to provide any kind of good or service to Change Healthcare, and includes the Supplier's employees, directors, agents, subsidiaries, affiliates, subcontractors, and other representatives. The Supplier Code of Conduct goes beyond compliance with local law and is based upon universal principles that align with Change Healthcare's values globally; therefore, it applies to all Change Healthcare Suppliers, regardless of location.

Compliance with the Supplier Code of Conduct

Suppliers and their employees, agents, and subcontractors (collectively referred to as "Suppliers") must adhere to this Supplier Code of Conduct while conducting business with or on behalf of Change Healthcare. Suppliers must promptly inform their Change Healthcare contact (or a member of Change Healthcare management) when any situation develops that causes the Supplier to operate in violation of this Code of Conduct. While Change Healthcare Suppliers are expected to self-monitor and demonstrate their compliance with this Code of Conduct, Change Healthcare may audit Suppliers or inspect Supplier's facilities to confirm compliance and any violations of this Code of Conduct that may jeopardize the Supplier's business relationship with Change Healthcare, up to and including termination.

Protection of Confidential Information and Change Healthcare Property

Change Healthcare's intellectual property is an important asset and critical to our business. Suppliers should understand its importance and protect Change Healthcare's intellectual property accordingly. Suppliers are expected to safeguard confidential Change Healthcare information. If a Supplier has access to confidential Change Healthcare information, it is to be used only in a manner permitted by Change Healthcare and protected at a minimum with the same care in which the Supplier safeguards its own information.

Suppliers should also respect Change Healthcare's physical and electronic assets and use them appropriately for business purposes. Suppliers must wear badges on Change Healthcare premises where required by Change Healthcare for security purposes and adhere to Change Healthcare security protocols. Suppliers are not permitted to publicly disclose Change Healthcare as a client or use the Change Healthcare name, logo, or trademark unless ized to do so.

Conflict of Interest

At Change Healthcare, we are transparent in our business dealings and avoid situations that put our individual interests in conflict with those of Change Healthcare or lead others to question our business objectivity. As a Supplier to Change Healthcare, any conduct or relationship that could present an actual or perceived conflict with Change Healthcare's interests should be disclosed to Change Healthcare. A conflict of interest might include, for example:

  • Significant ownership or other substantial financial interest in a healthcare services company or any entity that stands to benefit from the Supplier's business relationship with Change Healthcare.
  • A Supplier offering a Change Healthcare employee a consultancy, directorship, freelance commercial opportunity, or other financial or professional opportunities.
  • A Supplier's employment of or close connections to a covered government official who has influence over matters that could reasonably be expected to affect Change Healthcare's business.

A significant financial interest is any economic interest, including any interest as an owner, partner, stockholder, or holder of debt that might influence or appear to influence judgment. Investments that amount to 1% or more of the outstanding shares of a publicly traded company, or that are of such a dollar amount or percentage of net worth that could reasonably create the perception of a conflict, are generally considered significant.

Gifts & Gratuities

A Supplier is prohibited from offering or providing any gifts, meals, travel, or entertainment ("GTE") to Change Healthcare or Change Healthcare staff or on behalf of Change Healthcare or Change Healthcare staff for any purpose that is unlawful, unethical, or improper. Although gift giving is common in some parts of the world, caution must be taken; no GTE may be given to Change Healthcare staff while a deal is being negotiated. The giving or receiving of cash or a cash equivalent as a business gift to Change Healthcare or Change Healthcare staff or on behalf of Change Healthcare or Change Healthcare staff is also prohibited. Subject to the requirements above, GTE that is reasonable, appropriate, does not exceed USD 150 in value, and does not violate applicable law is acceptable.

Human Rights

Change Healthcare is committed to respecting human rights. Our commitment includes identifying, preventing and mitigating any adverse human rights impacts of our activities where possible. We expect our Suppliers to share the same respect for human rights, including those principles recognized in international human rights standards such as the Universal Declaration of Human Rights (UDHR). Suppliers' approaches to human rights should be consistent with the UN Guiding Principles on Business and Human Rights. Suppliers must comply with all applicable legal requirements related to human rights. When local laws are in conflict with international human rights standards, suppliers should comply with the law while seeking to advance the underlying principles of the Change Healthcare Supplier Code of Conduct.

Employment Laws/Workplace Relations

Change Healthcare is committed to ensuring a safe, fair, respectful and inclusive workplace for our employees around the globe, and we value the individual differences, backgrounds, experiences and capabilities of each employee. We expect our Suppliers to share this commitment and uphold the principles laid out by the International Labour Organization's (ILO) Declaration on the Fundamental Principles and Rights at Work.

Change Healthcare is committed to ensuring modern forms of slavery and human trafficking are not present in our supply chains and in our business. Supplier shall ensure that all work is voluntary. Suppler shall not traffic persons or use any form of slave, forced, bonded, indentured, or prison labor. Involuntary labor includes the transportation, harboring, recruitment, transfer, receipt, or employment of persons by means of threat, force, coercion, abduction, fraud, or payments to any person having control over another person for the purpose of exploitation.

Supplier shall not withhold workers' original government issued identification and travel documents. Supplier shall ensure that worker's contracts clearly convey the conditions of employment in a language understood by the workers. Supplier shall not impose unreasonable restrictions on movement within the workplace or upon entering or exiting company-provided facilities.

Suppliers are expected to provide and foster a diverse and inclusive workplace. Change Healthcare promotes a "no tolerance" standard with respect to discrimination and harassment in the workplace. This includes prohibiting any form of harassment, victimization, or discrimination on the basis of characteristics unrelated to job requirements that are protected by law, such as race, color, sex, sexual orientation, gender identity or expression, religion, age, marital status, national origin, ancestry, pregnancy or maternity, medical condition, citizenship, and physical or mental disability.

Health and Safety

Change Healthcare Suppliers are expected to integrate sound health and safety management practices into all aspects of business, and must, without limitation:

  • Provide a safe and healthy work environment and fully comply with all safety and health laws, regulations, and practices including those applicable to the areas of occupational safety, emergency preparedness, occupational injury and illness, industrial hygiene, physically demanding work, machine safeguarding, sanitation, food, and housing. Adequate steps must be taken to minimize the causes of hazards inherent in the working environment.
  • Prohibit the use, possession, distribution, or sale of illegal drugs while on Change Healthcare-owned or leased property.

Environmental Regulations and Protection

Change Healthcare recognizes its social responsibility to protect the environment and expects its Suppliers to share its commitment by responding to challenges posed by climate changes and working toward protecting the environment. As a part of this commitment, all Change Healthcare Suppliers must, without limitation:

  • Comply with all applicable environmental laws and regulations regarding hazardous materials, air emissions, waste, and wastewater discharges, including the manufacture, transportation, storage, disposal, and release to the environment of such materials.
  • Endeavor to reduce or eliminate waste of all types, including water and energy, by implementing appropriate conservation measures in their facilities, through their maintenance and production processes, and by recycling, re-using, or substituting materials.
  • Obtain, maintain, and keep current all required environmental permits and registrations and follow the operational and reporting requirements of such permits.
  • If applicable, identify the chemicals or other materials being released that pose a threat to the environment and manage them appropriately to ensure their safe handling, movement, storage, use, recycling, or reuse and disposal.

Supplier Diversity

Change Healthcare recognizes the value of a diverse supply chain and encourages opportunities for small and diverse businesses in a manner that promotes awareness, builds strategic relationships, and develops successful and mutually beneficial partnerships. Suppliers should support diverse businesses throughout their own supply chains, providing these businesses with a fair opportunity to bid and acquire contract opportunities. Suppliers should also support Change Healthcare's own supplier diversity initiatives including providing relevant reporting.

This Code of Conduct is based in part on the principles outlined in the International Labour Organization's 1998 Declaration on Fundamental Principles and Rights at Work. We expect our Suppliers to develop and implement appropriate internal business processes to ensure compliance with this Code of Conduct.