Vendor Code of Conduct
I. Purpose and Scope
The purpose of this Vendor Code of Conduct is to outline the compliance and ethical standards that vendors and suppliers are expected to adhere to when conducting business with Spring Health.
Spring Health expects all vendors and their representatives to conduct themselves in a professional and ethical manner at all times and comply with all applicable laws, rules, and regulations.
All vendors and their representatives are expected to be familiar with Spring Health’s Vendor Code of Conduct and adhere to the standards and policies set forth in this Code.
II. Privacy and Data Protection
Vendors are expected to protect confidential information and must adhere to applicable privacy and security laws, regulations, contractual requirements, and standards based on industry best practices. Vendors must adopt and maintain policies and procedures that provide adequate safeguards for any personal, proprietary and confidential information, including information that they access, receive or process on behalf of Spring Health. Vendors should recognize that unauthorized use or disclosure of such information may have personal, legal, reputational and financial consequences for Spring Health and our members.
III. Ethical Business Practices
Spring Health is committed to conducting business in accordance with the highest ethical standards and in compliance with all applicable laws, rules and regulations. Vendors are expected to share Spring Health’s principles, uphold our standards and maintain policies and procedures to ensure compliance.
Anti-Bribery and Corruption
Spring Health does not tolerate bribery or corruption involving its employees, vendors, agents or other business partners as outlined in the Anti-Bribery and Corruption Policy POL 013. Vendors are expected to fully comply with requirements of all applicable laws and regulations designed to combat bribery and corruption, including the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act, as well as local anti-bribery and anti-corruption laws.
Vendors are strictly prohibited from corruptly offering, providing, paying, authorizing, promising, soliciting or receiving anything of value, directly or indirectly, for the purpose of obtaining or retaining business or any improper business advantage for or from Spring Health. This prohibition extends not only to Spring Health personnel, representatives and agents, but also to public officials (including candidates for office, employees or officers of state-owned or controlled enterprises), employees or officers of counterparties, clients, customers or suppliers, as well as their relatives, friends, agents, and associates. Vendors are also prohibited from facilitating payments made to public officials to expedite or secure performance of a routine, non-discretionary governmental action.
Vendors and other suppliers acting on behalf of Spring Health, including agents and business partners, are expected to maintain appropriate policies and procedures and act at all times in a manner consistent with this Code.
Gifts, Gratuities and Business Courtesies
Vendors must not provide lavish or otherwise inappropriate gifts, fees, favors or other compensation, including travel and entertainment, that are intended to influence, or may appear to influence, a Spring Health business decision. Spring Health personnel are prohibited from accepting lavish and non-customary Gifts, Gratuities and Business Courtesies from vendors in accordance with Spring Health’s Gifts, Gratuities, and Business Courtesies Policy POL 003.
The offering of lavish and non-customary gifts, travel or entertainment may create an inappropriate obligation or expectation or appearance of an improper exchange even if no benefit was ultimately provided. Spring Health prohibits vendors from extending gifts or offering items of value to Public or Foreign Officials on behalf of Spring Health or with the intent to benefit Spring Health.
Conflicts of Interest
Vendors must avoid improprieties and conflicts of interest or the appearance of either, as well as disclose any potential Conflicts of Interest to Spring Health, as outlined in our Conflict of Interest Policy POL 003.
Generally, a conflict of interest occurs when an individual or an institution enters into any type of relationship that interferes with, compromises or gives the appearance of compromising the professional judgment or obligations of the individual or institution.The appearance of a conflict of interest can raise doubts or arouse suspicions among co-workers, customers, investors and others that can be damaging and cause reputational harm to Spring Health.
Grievance Mechanism
Vendors are expected to maintain a process through which employees can raise workplace concerns without fear of retaliation. The grievance mechanism should be transparent and understandable to employees, and should ensure the protection of whistleblowers.
Spring Health has implemented a mechanism that empowers vendors and third parties to voice any concerns they may have regarding their activities in connection with our partnership.
IV. Labor and Human Rights
Spring Health recognizes its responsibility to protect human rights. Vendors are expected to have practices that apply to all employees, suppliers, and their supply chains and address the following topics:
Slavery, Forced Labor and Human Trafficking
Spring Health does not tolerate slavery, forced labor, or human trafficking in any form and Spring Health will not knowingly work with vendors who engage in these practices or permit their subcontractors to engage in these practices. Vendors must not engage in practices associated with forced labor. Additionally, vendors must not engage in or support human trafficking and are encouraged to implement due diligence measures to ensure that no human trafficking exists within their extended supply chains.
Child Labor
Vendors must not employ child labor, and should take the necessary preventive measures to ensure that it does not employ anyone under the applicable legal minimum age of employment.
Respect, Inclusion and Non-Discrimination
Spring Health is committed to treating employees and vendors with respect at all times. Vendors are required to comply with all applicable laws regarding discrimination in hiring and employment practices. Vendors are expected to maintain a workplace free of discrimination, prejudice, harassment, victimization, and to not tolerate any other form of inappropriate behavior or abuse on any grounds, including but not limited to age, disability, ethnic or social origin, gender, gender identity, nationality, race, sexual orientation, marital status, parental status, pregnancy, political convictions, religious beliefs, or veteran status. Vendors are expected to maintain an environment free of harassment, violence and abuse (physical or verbal) at all times.
Safe and Healthy Work Environment
Vendors must provide a working environment that minimizes health and safety risks and supports accident prevention and ensures the health and safety of all personnel and all others affected by their activities. Vendors are required to, and must require their subcontractors to, comply with all applicable health and safety laws and regulations in the jurisdictions in which they operate.
V. Diversity, Equity, and Inclusion
Spring Health believes that diversity, equality and inclusion are social and economic imperatives and looks to its vendors to share this commitment in their operations, workforces and within their supply chains.
Workplace Diversity and Inclusion
Vendors and their subcontractors are encouraged to engage a workforce that is inclusive of diverse groups. Vendors are strongly encouraged to take proactive steps to include the hiring of historically underrepresented groups, such examples are of workers who self-identify as minorities, ethnically diverse, women, LGBTQ , Veteran, or a person with a disability.
VI. Business Continuity and Emergency Preparedness
Vendors are expected to adhere to contractual and regulatory requirements in managing business continuity risk and ensure the availability and continuity of critical services during a Business Continuity Preparedness event. Depending on the relevant applicability and nature of their respective businesses, vendors should have plans in place for their business and services to continue with minimal interruption in the event of an emergency, crisis situation, weather or other natural disaster, pandemic or epidemic, terrorist/security related event, strikes, labor or other resource constraints, system and/or facilities outage or unavailability, power outage, and/or telecommunication outage or unavailability, so as to ensure that there will be no significant disruption to Spring Health’s business, operations and reputation.
VII. Reporting Violations
This Code sets forth expectations for current and future vendors. All new and existing vendors are expected to meet these minimum expectations and to aspire to make continuous improvements to their businesses as noted herein.
Integrity concerns, including but not limited to violation of applicable Spring Health policies, laws or regulations, the agreement or this Code, may be reported via the Spring Health Integrity Hotline.
Retaliation of any kind against an individual who reports concerns in good faith is prohibited. Spring Health’s reporting hotline is available 24 hours a day, 7 days a week:
● Integrity Hotline Website: www.lighthouse-services.com/springhealth
● Integrity Hotline Toll-Free Telephone(s):
○ English speaking USA and Canada: 833 490 0007
○ Spanish speaking USA and Canada: 800 216 1288
○ Spanish speaking Mexico: 01 800 681 5340
○ French speaking Canada: 855 725 0002
If a vendor is found to be in violation of the requirements of this Code, the vendor is expected to inform Spring Health immediately or as soon as is practicable and remedy any such violation in a timely and sensitive manner.
VIII. Compliance with Code, Policies and Laws
Spring Health is committed to continuously reviewing and updating this Code. Therefore, this Code is subject to modification from time to time.
Spring Health does not tolerate unlawful conduct by its vendors. Vendors must not directly or indirectly engage in, or facilitate the engagement of others in, the deliberate violation of any applicable law. Vendors must also comply with and abide by the relevant Spring Health policies mentioned herein. Vendors are expected to ensure the same of their agents, subcontractors, intermediaries, and employees.
The contents of this Code are additional to and do not in any way affect or prejudice any of Spring Health’s rights and remedies under relevant contracts with each vendor. In the event of any non-compliance with the requirements of this Code, applicable Spring Health policies, laws, or regulations, or breach of contract, Spring Health reserves its rights and retains the sole discretion to exercise any relevant contract remedies and/or local laws and regulations.
The failure or omission by Spring Health to insist upon strict performance and compliance with any of the provisions of this Code or its policies at any time must in no way constitute a waiver of its rights. In the event of any conflict or ambiguity between any provision of this Code and the provisions of any relevant contract with any vendor, the provisions of that contract will prevail.
IX. Contact
If you have questions about this policy, please contact compliance@springhealth.com