Social Media

Online communication channels that provide an opportunity for content sharing, individual input of information, and interaction. Includes websites, chat rooms, blogs, news feeds, social networking sites, and special applications dedicated to posting and sharing comments, articles, opinions, ideas, information, and images.

Money Laundering

Making money derived from unlawful activities “clean” by making it appear that the money came from legitimate sources or transactions.

Need to Know

Team members who have a “need to know” information require access to that information (often confidential in nature) to do their jobs. If you are in doubt about whether a particular individual within the Company has a “need to know,” please contact Human Resources, Employee Relations, or the Office of Ethics and Compliance or Legal.


Taking adverse action against a team member in response to that team member’s good faith report of an actual or suspected violation of our Code, Company policies or legal requirements.

Protected Health Information

Protected health information (PHI), which is a subset of PII, includes individual health information such as medical history and diagnoses, physician orders, treatment records, and prescription and payment histories.

Personally Identifiable Information

Personally identifiable information (PII) is any piece of information that can potentially be used to uniquely identify, contact, or locate a specific person. Examples include name, address, photo, birth date, phone number, health information, social security number or credit or financial information.

Nonpublic Information

Information about a business organization that is not generally available to or known by the public (also called “inside information”).

Material Information

Information that an investor likely would consider important in deciding whether to buy, hold or sell securities of a company.

Legal Hold

A legal hold suspends all document destruction procedures to preserve appropriate records under special circumstances, such as anticipated or actual litigation or government investigations. Legal identifies what types of records or documents are required to be placed under a legal hold.


A form of corruption that involves two parties agreeing that a portion of the money paid, or due to be paid, will be given back to the purchasing party in exchange for making the deal.

Intellectual Property

Knowledge, ideas, discoveries, formulas, inventions and other intangible assets that have commercial value and are protected under copyright, patent, service mark and trademark laws. Additional examples of intellectual property include technical inventories, brands and logos, software code, presentations, databases, customer lists, process documents, and product designs and roadmaps.


Unwelcome words, actions or behaviors that denigrate, disrespect or belittle an individual or create a hostile, offensive or intimidating work environment because of a protected category. Sometimes, a person’s conduct may be considered harassment even if it was not intended to be offensive.

Government Officials

Employees or agents of any government anywhere in the world, even low-ranking employees or employees of government-owned, affiliated or controlled entities. The term also includes political parties and party officials, candidates for political office, and employees of public international organizations, such as the United Nations.

Good Faith

Acting in “good faith” means making a genuine effort to provide honest, complete, and accurate information.


Family includes spouse, children, siblings, parents, grandparents, grandchildren, aunts, uncles, nieces, nephews, cousins, step relationships, and in-laws.


The Company’s reporting service, administered by a third party, through which team members and others can ask questions or raise concerns about our Code of Conduct, Company policies or legal requirements.

Conflict of Interest

Situations in which a team member’s personal considerations or interests have the potential to affect, or could have the appearance of affecting, their judgment or objectivity in their work for Change Healthcare.

Change Healthcare Confidential Information

Generally, Change Healthcare’s confidential information includes any information that is not disclosed to individuals outside of Change Healthcare or any information that could be useful to our competitors or harmful to the Company if it were disclosed. The term includes personally identifiable information (PII), protected health information (PHI), strategic and business plans, mergers and acquisitions, pricing, financial data, inventions, and Change Healthcare’s proprietary information, among other data.

Company Assets

Anything Change Healthcare uses to conduct business, including equipment, supplies, vehicles, furnishings, computer systems, software, phones and other wired and wireless devices. Also includes information, trade secrets, personnel, our brand, and our reputation.

Close relative

Includes spouse, significant other, child, parent, in-law or other devoted family member.

Cash Equivalents

Loans, stock, stock options, bank checks, travelers’ checks, check or cash cards, gift certificates, money orders, investments securities or negotiable instruments.


Offering, promising or giving anything of value to gain an improper advantage or favorable business decision.

Anything of Value

Anything of value is broadly defined and may include cash, cash equivalents, gifts, meals, entertainment, recreation, charitable donations, loans, travel expenses (airfare, hosting, etc.), job placements, consulting contracts, operational support, educational support, or other payments, or free or discounted items.