Davita Code of Conduct 2013 - 36

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PROTECTION AND PROPER USE OF VILLAGE ASSETS
Q: I am a small business owner and perform consultations when I am not at DaVita. Can I email clients and fax
forms during my lunch break using DaVita computers or fax machines?
A: No. All DaVita assets and supplies are used to further DaVita’s business. Teammates should conduct outside
business on their own time and with their own resources.
Q: My cousin works in the billing department of another dialysis company. Can we discuss our jobs when we
are together?
A: There should be no problem, as long as you do not discuss proprietary, patient or confidential information. To
avoid a conflict of interest, you should inform your supervisor or People Services of any close friends or family
members employed by a competitor.
INSIDER TRADING
Q: My family and friends occasionally ask me whether they should buy DaVita stock. Can I give them my opinion?
A: Avoid any specific discussion of company plans, performance and or other important developments that have
not been made public. You should not make recommendations to anyone regarding buying or selling of DaVita
stock. The same rules about “inside” information apply whether you buy or sell stock yourself or if you give the
information to someone else, also known as a “tip.” If stock is purchased based on non-public information or
“tips” this can be a violation of federal security laws for the person who gave the tip as well as the person who
received the tip.
ANTI-CORRUPTION, ANTI-BRIBERY AND ANTI-KICKBACK LAWS
Q: An affiliated physician is short-staffed at his office practice. Is it okay for my administrative assistant to help
him with scheduling and paperwork?
A: No. Providing office assistance to a potential referral source, such as an affiliated physician, at no charge may
be considered a kickback.
Q: A local surveyor responsible for overseeing my facility told me that I can pay him an annual fee to limit the
number of surveys we receive in the course of a year. Is it okay?
A: No. Paying a surveyor to survey you less frequently than normal is a bribe. If anything like this ever arises, refuse
the request and immediately contact a member of Team Quest.
Q: A consultant has been negotiating a government contract for DaVita and asks me to be reimbursed for a first
class airline ticket to an undisclosed location. Should I inquire about the nature of the trip?
A: Yes. While the trip may be legitimate, an incomplete expense report is a red flag that the consultant may have
improperly provided something of value to a government official or employee. You should inquire further about
the business reason for the trip, ask for a copy of the airline ticket or invoice, and immediately contact a member
of Team Quest if you suspect or know something is not right with the travel.
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Davita Code of Conduct 2013

Table of Contents for the Digital Edition of Davita Code of Conduct 2013