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.


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

Cardholder Data

Any Personal Information (PI) associated with a person who has a credit or debit card. At a minimum, cardholder data consists of the full account number and may also include the expiration date and/or the service code. Sometimes referred to as credit card or “PCI” data.

Cash Equivalents

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

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.

Confidential Information (Change Healthcare)

Information that could cause great harm to Change Healthcare if disclosed inappropriately. Examples include protected health information (PHI), personal information (PI), internal policies, standards, and procedures, and Change Healthcare proprietary software and source code.

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.


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.

Good Faith

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

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.


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.

Human Trafficking

Human Trafficking includes, without limitation, recruiting, harboring, transporting, providing, or obtaining a person for labor or services through the use of force, coercion, fraud or deception, the abuse of power or of a position of vulnerability, or the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation. Exploitation includes, without limitation, involuntary servitude, peonage, debt bondage or slavery, the removal of organs, and sex trafficking, or other forms of exploitation.

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.

Internal Use Only (Change Healthcare)

Information that may be shared among team members, but not with outside parties unless an authorized nondisclosure agreement (NDA) has been signed. Examples include weekly status reports, team member contact information, and software documentation.


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.

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.

Material Information

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

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.

Nonpublic Information

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

Personal Information

Personal information (PI) includes any information about, or associated with, any individual. PI can be in any format, whether in oral, written, paper, or electronic. Examples include name, address, birth date, phone number, or social security number.

Protected Health Information

Protected Health Information (PHI) is any individually identifiable health information, that: (1) is created or received by a health care provider, health plan, or health care clearinghouse; and (2) relates to the past, present, or future physical or mental health or condition of an individual; the provision of health care to an individual; or the past, present or future payment for the provision of healthcare to an individual; and (3) directly or indirectly identifies the individual.


Includes spouses, registered domestic partners, children, siblings, parents, in-laws, aunts, uncles, nieces, nephews, cousins, grandparents, grandchildren, step-relatives, and other members of the Team Member’s household.

Restricted (Change Healthcare)

Information intended for a limited group of individuals specified by name. Inappropriate disclosure could result in serious detriment to Change Healthcare. Examples include merger and acquisition information, financial forecasts or results not yet public, and strategic planning information not yet public.


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.

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.