We Are Agile
We Speak Up
We understand our right and our responsibility to ask questions and voice concerns when we encounter something that does not seem right. When we Speak Up, we demonstrate our integrity and show we have the courage to do the right thing, the right way, every day.
How do I ask for guidance, voice a concern or report an incident?
In many cases, your manager is in the best position to help you. However, if for any reason you are not comfortable talking about an issue with your manager, you may contact the Office of Compliance and Ethics, your Business Unit Compliance Lead, People Solutions, Legal or ChangeHealthcareEthicsLine.com. Refer to Speak Up for more information.
No matter who you contact or what resource you choose, your concern will be promptly addressed and handled with the appropriate level of confidentiality.
We do not tolerate retaliation against a team member for raising a question or reporting potential misconduct in good faith. Anyone who retaliates is subject to disciplinary action, which may include termination of employment, or no longer be able to provide services to the Company.
Examples of issues you should report
- Discrimination or harassment
- Privacy concerns
- Conflicts of interest
- Theft, fraud, bribery
- Environmental or safety concerns
- Workplace violence, threats or bullying
- Accounting or other financial issues
- Inappropriate gifts or entertainment
- Intimidation or retaliation
- Other threatening or concerning behavior
- Code violations
- Policy violations
- Legal requirement violations
Note: This is not a complete list of issues you should report. Anytime you see or suspect something is not right, Speak Up and voice your concern.
Communications with Governmental Entities
Change Healthcare team members may communicate, cooperate or file a complaint with any U.S. federal, state or local governmental or law enforcement entity concerning possible violations of any legal or regulatory requirement, and may make disclosures to any governmental entity that are protected under the whistleblower provisions of any law or regulation, so long as (1) such communications and disclosures are consistent with applicable law and (2) the information disclosed was not obtained through a communication that was subject to the attorney-client privilege (unless disclosure of that information would otherwise be permitted by an attorney pursuant to the applicable federal law, attorney conduct rules or otherwise). Any agreement inconsistent with the above language between Change Healthcare and a team member is deemed invalid and will not be enforced by the Company.
Our Investigation Process
We promptly investigate all reports of conduct that may violate our Code, policies or legal requirements. Depending on the nature of the suspected conduct, it may be investigated by Employee Relations or Legal. All team members are expected to be truthful and fully cooperate with any investigation into an alleged violation of our Code, our policies or legal requirements. Team members who fail to do so may be disciplined, possibly having their jobs terminated, or no longer being able to provide services to the Company.
Investigation Process:
The Integrity of Change - Our Code of Conduct
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