Administrative Manual

                                                                     BRIBES

Policy Number:   12.02                                                                                           Page 1 of 1

Objective:   To establish a policy prohibiting the use or acceptance of bribes by Covenant HealthCare colleagues (directors, officers, employees, medical staff, volunteers, suppliers, vendors, contractors, consultants and agents).

Scope:           All Covenant facilities and wholly owned entities.

Policy:          No funds or other property shall be used to bribe or attempt to bribe any public official, employee, agency, or organization to make any decision, take any action or cause inaction. Covenant HealthCare colleagues are prohibited from accepting any funds or other property intended to cause the colleague to make any decision, take any action or cause inaction.  Funds of the organization used to influence or attempt to influence, any decision, action, or inaction must be in compliance with applicable Federal and State Law.  Any employee who believes that there has been an attempt at bribery is obligated to report his or her suspicion to their respective Vice President, or Corporate Compliance.

This policy is intended to support and complement the Covenant Code of Conduct.

Related Policies/Procedures:   Code of Conduct

Reviewed by:       Executive Team 11/10/99, Administration 9/2009, 9/2012

Effective date:     12/6/99, 12/6/02, 9/30/05, 9/2009, 9/2012, 9/2015

Review date:        9/2018

Approval:

_____________________________________________                  September 2015                

Edward Bruff, President/CEO                                                           Date