Frequently asked questions regarding SSMHC'S corporate responsibility process and anonymous Help Line

SSM Health Corporate Responsibility Process - Who to Ask

SSM Health Corporate Responsibility Process: Who to Ask
1st choice	Ask my supervisor
2nd choice	Ask the corporate responsibility process contact person at the entity
3rd choice	Ask a senior manager in the entity
4th choice	Call the System Vice President - Corporate Responsibility at the System Office, Mindy Phillips, (314) 989-2647.
5th choice	Contact the anonymous CRP Help Line at 1-877-4CRP-ASK or www.crpHelp Line.ethicspoint.com.

About SSMHC’s Help Line Vendor -- EthicsPoint

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool to assist management and employees to work together to address fraud, abuse, and other misconduct in the workplace, all while cultivating a positive work environment.

Why do we need a system like EthicsPoint?

As you are aware, our Mission calls each of us to ensure that we provide exceptional care to the people we serve. Likewise, we must also ensure that everything we do is ethical, legal and complies with federal regulations. The Corporate Responsibility Process, or CRP, is our formal process to ensure our compliance.

It is vitally important for you to know that if you feel something is not right — if something seems unethical, illegal, or not in compliance with regulations — you should tell someone. You are first encouraged to talk with your supervisor, manager, or CRP entity or corporate contacts. However, if you wish to remain anonymous, our CRP Help Line is an available resource.

In 1998 SSMHC established the CRP Help Line. We believed that an effective reporting system would support our other efforts to foster a culture of integrity and ethical decision-making. In 2012, we purchased the EthicsPoint tool which allowed us to expand the options available for you to report compliance related issues or concerns. Employees may now submit questions or concerns through www.crpHelp Line.ethicspoint.com.

May I report using either the Internet or the telephone?

Yes. With EthicsPoint, you have the ability to file a confidential, anonymous report via the telephone by calling 877-4CRP-ASK and speaking with an EthicsPoint Intake Specialist or through the Internet. Both options are available for your use 24/7.

What type of situations should I report?

The EthicsPoint system is designed for employees to report any violation of our Code of Conduct (for instance, billing fraud, conflicts of interest, privacy violations, etc.). Please continue to direct questions related to personnel matters such as discrimination, harassment, pay, time-off, etc. to your local human resources contact.

If I see a violation, shouldn't I just report it to my manager or human resources and let them deal with it?

When you observe behavior that you believe violates our code of conduct, we expect you to report it. If you have questions, or want to report a concern, please talk to your supervisor. If you cannot talk to your supervisor, contact a senior manager at your entity. If you do not feel comfortable talking to a senior manager, please contact your CRP contact, or Mindy Phillips, System Vice President - Corporate Responsibility.

We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that we have partnered with EthicsPoint. We would rather you report anonymously than keep the information to yourself.

Why should I report what I know? What’s in it for me?

As SSMHC employees, we are all responsible for the decisions we make and have an obligation to uphold the ethical and moral values of our organization. If our organization is injured or damaged as a result of inappropriate or illegal conduct, we are all harmed. Please raise questions about any conduct that you observe or become aware of that you think is not in line with our mission and values.

We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting the appropriate people know of inappropriate conduct. By working together, we can maintain a healthy and productive environment.

Does management really want me to report?

We certainly do. In fact, we need you to report. You know what is going on in your entity - both good and bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on SSMHC and our people. Also, offering positive input may help identify issues that can improve our processes and performance.

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPoint secure server to prevent any possible breech in security. EthicsPoint makes these reports available only to specific individuals within SSMHC who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports in the utmost confidence.

Isn’t this system just an example of someone watching over me?

The EthicsPoint system makes a positive contribution to our overall philosophy, and allows us to assure a safe, secure, and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern. Effective communication is critical in today’s workplace and this is a great tool to enhance that communication.

We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment.

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Security & Confidentiality of Reports

It is my understanding that any report I send from my entity’s computer generates a server log that shows every web-site that my computer (PC) connects with. Won’t this log identify me as submitting a report?

EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available. In fact, EthicsPoint is contractually committed not to pursue a reporter’s identity.

If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside our work environment (such as one located at an Internet café, at a friend’s house, etc.) through the EthicsPoint secure website.

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is totally maintained. Plus, EthicsPoint is contractually committed not to pursue a reporter’s identity.

Additionally, SSMHC encourages employees to report possible instances of wrong doing and makes anonymous reporting available since that route may be preferred by some. We would not betray our employees trust by attempting to identify anonymous reporters.

Is the telephone Help Line confidential and anonymous too?

Yes. Just as before, you may remain anonymous should you report a concern using the telephone. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the EthicsPoint Web site. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the report for identifying yourself, if you wish.

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Tips & Best Practices

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?

Consistent with our mission and values, SSMHC promotes ethical behavior. The Corporate Responsibility Process (CRP) is designed to help all of us make good decisions. It also helps to ensure that our values are reflected in everything we do. Corporate Responsibility applies to all employees and anyone who acts on behalf of SSM Health. All unethical conduct, at any level, ultimately hurts the SSMHC and all employees, including you. You only have to consider what happened in recent corporate scandals to see the disastrous effects that a seemingly harmless lapse in ethics can have on an otherwise healthy company. So if you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it.

I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

At SSM Health, you are responsible for asking questions any time you believe our work processes or requirements are not in line with our mission and values.

For instance:

• Does the activity conform to legal and ethical requirements, and is it in line with the policies of SSM Health?
• Is this a decision you feel uncomfortable with? Does it go against the policies of SSM Health or our commitment to exceptional health care services?

If you remain uncertain about the conduct and do not feel comfortable discussing it with a supervisor or other management contact, file a report. EthicsPoint can help you prepare and file your report. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you weren't sure.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

Like our existing processes, the EthicsPoint system and report distribution are designed so that implicated parties are not notified or granted access to reports in which they have been named.

What if I remember something important about the incident after I file the report? Or what if the CRP contact has further questions for me concerning my report?

When you file a report via the Help Line number or through the internet, you receive a unique user name and are asked to choose a password. You can return to the EthicsPoint system again and access the original report to add more detail or answer questions posed by an SSMHC entity representative. We strongly suggest that you return to the site in the time specified to answer questions. We’ve now entered into an “anonymous dialogue” where situations are not only identified but can be resolved, no matter how complex.

Are these follow-ups on reports as secure as the first one?

Yes, all EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

How does SSMHC investigate concerns?

EthicsPoint notifies your entity’s CRP Contact when a concern is received. The CRP Contact then commences an appropriate investigation, using internal or external resources with expertise in conducting investigations. The information in your report is shared with appropriate investigation team members, and the concern is investigated promptly and discreetly.

What if I face retaliation?

SSMHC strictly forbids any retaliation against any person who reports a concern. Complaints made in good faith will not expose you to any sanctions, regardless of whether the underlying facts prove to be correct or result in any corrective action. If you believe you have faced retaliation of any kind, please report it so that we can investigate.

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