Guidance for Vendor Representatives

The Wheaton Franciscan System’s corporate compliance program helps the organization, its employees and contractors abide by all applicable laws, regulations and policies. The program is consistent with the Mission, Vision and Values of the Wheaton Franciscan System. The Wheaton Franciscan System’s goal is to do business with associates, including but not limited to vendors and service providers, who abide by similar principles. This brochure is intended to familiarize you and your company with our compliance policies and practices regarding the laws and regulations that govern our operations.

We value the vital contribution our vendor representatives make to the quality care we provide. We ask that you review this brochure to better enable you, your company and our organization to conduct business in a mutually satisfactory manner.

The Wheaton Franciscan System is committed to the highest ethical and legal business practices and complies with the laws and regulations that pertain to our operations. We also are committed to quality care as we continue the healing ministry of Jesus in our organization. We reflect ethical business practices in all we do, and we expect our vendor representatives to share in this commitment throughout their relationship with us.

The Wheaton Franciscan System is committed to living out the healing ministry of Jesus by providing exceptional and compassionate health care service that promotes the dignity and well being of the people we serve.

The Wheaton Franciscan System requires all employees, including physicians, to remain free from any actual or potential conflicts of interests, including even the appearance of a conflict. Therefore:

• Employees may not solicit nor accept gifts, gratuities, favors, or other business courtesies from a vendor representative.
• Employees may not accept cash or cash equivalents (e.g., gift certificates). Perishable or consumable gifts that are given to a department or group are acceptable as long as such items are not lavish and are not provided frequently.
• Employees may not solicit, receive or offer payment of money or anything of value, either directly or indirectly, in exchange for the referral of any item or service provided by the System.
• Stipends and other cash awards received for presentations or consulting efforts developed or presented during normal working hours and/or related to duties and responsibilities with the organization must be endorsed over or paid directly to the organization.

In an effort to help our employees abide by our policies, we are requesting that our vendor representatives refrain from making any offerings to our employees that might violate (or be perceived as violating) the above.

When working in conjunction with our organization, vendor representatives are expected to:

• Operate in compliance with all applicable legal requirements and our organization's policies
• Never pursue any business opportunity or relationships that would compromise our ethical standards or violate a law, regulation or corporate policy
• Respect the rights and dignity of our employees and patients
• Protect the physical and intellectual property of the System and any organizational assets against loss, theft, destruction, misappropriation, and misuse
• Not use for personal gain any information obtained as a vendor representative, including confidential or proprietary information
• Not offer or accept any bribes, kickbacks or inducements in connection with performing duties for any of our organizations
• Maintain the confidentially of patient information
• Report a suspected violation of any law, regulation or policy.

The corporate compliance program fosters an environment in which employees, affiliates and vendor representatives are encouraged to report concerns about business practices. A toll-free Compliance Line is available as a reporting mechanism whereby employees, medical staff, vendor representatives, and others associated with the System can report, without fear or retaliation, suspected violations or issues of non-compliance. Callers may remain anonymous, if they so desire.

An awareness and understanding of our corporate compliance program allows your company to better meet our needs while maintaining our commitment to the highest ethical standards. If you have any questions about our compliance program or any of the information outlined above, please contact Julie Ward, vice president of compliance at 630/784-2524.