We Earn Trust
We Give and Receive Appropriately
We recognize that the exchange of gifts or entertainment may help develop and strengthen our business relationships – but we do not give or receive gifts or entertainment that influence, or even appear to influence, business decisions. We give and receive gifts or entertainment in an ethical way that does not violate our Code, Company policies, legal requirements or third-party policies.
All team members should study the Change Healthcare Gifts and Entertainment Policy to learn the right way to give or receive an appropriate business courtesy. Whether giving or receiving a gift or entertainment, the Gifts and Entertainment Policy requires a team member to determine whether the courtesy is appropriate and lawful.
This chapter describes the first steps you should take when considering giving or receiving a business courtesy, but you should always consult the Gifts and Entertainment Policy, and speak with your manager and Business Unit Compliance Lead when you are unsure if a particular business courtesy is appropriate.
All gifts and entertainment, whether given or received, must meet Change Healthcare’s Criteria for Acceptable Business Courtesies.