Our Commitment
MJHS/Elderplan is an organization that prides itself on strong values of responsibility and integrity. We are committed to professional integrity, legal compliance and ethical conduct. The MJHS/Elderplan Code of Conduct (The Code) is our set of rules and standards regarding organizational values, beliefs, and ethics, as well as matters of legal compliance that govern the conduct of our organization and its employees, leadership, and other affiliated individuals. We are responsible for adhering to the Code and will be held accountable for failure to do so. It serves as a key component of our Compliance Program and summarizes the Organization’s standards of conduct and compliance policies and procedures.
For this Code to be effective, everyone needs to know, understand, and follow its standards and requirements. MJHS/Elderplan is committed to an environment where open, honest communications are the expectation, not the exception. Should you become aware of a potential violation of this Code, the law or our policies, as a MJHS/Elderplan employee, it is your duty to report such concerns in a timely manner. MJHS/Elderplan has contracted with EthicsPoint, a third-party vendor specializing in a comprehensive and confidential reporting system.
This system is designed to assist management and employees in working together to address potential fraud, waste, abuse and other compliance related concerns in the workplace, while maintaining a positive work environment. It allows you to file a report or inquiry through EthicsPoint and directly links you to the third-party reporting page where you will be presented with a series of questions relating to the concern. Please note, you may submit your report anonymously. You will also have the option to contact EthicsPoint directly via a toll-free number to provide the information over the phone to an EthicsPoint representative, which also may be done anonymously. Individuals are encouraged to submit reports pertaining to potential non-compliance concerns related to The Code, policies and procedures, rules and regulations, including fraud, waste, and abuse, or other irregularities/improprieties. In addition to such concerns, there is also the ability to seek guidance as well as submit questions or suggestions.
The information you provide will be sent to us by EthicsPoint on a totally confidential and anonymous basis, should you choose to file your report anonymously. All reports shall be reviewed and investigated in accordance with current MJHS/Elderplan procedures. MJHS/Elderplan policies prohibit intimidation, retaliation, or retribution against anyone who makes a good-faith report or inquiry about breaches of policy or regulations or for seeking guidance regarding policy or regulation, asking questions or making suggestions.
About EthicsPoint
What is EthicsPoint?
EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX Global to assist management and employees in working together to address fraud, waste, abuse and other misconduct in the workplace, while cultivating a positive work environment.
Why do we need a system like EthicsPoint?
- MJHS/Elderplan chose EthicsPoint as its provider for Compliance and Ethics Hotline reporting.
- We believe that our employees are our most important asset. By creating open channels of communication, we can better promote a positive work environment and maximize productivity.
- Even though MJHS/Elderplan is not a public company, having an independent reporting system like EthicsPoint is considered “best practice” because it provides an effective reporting system that will enhance our other efforts to foster a culture of integrity and ethical decision-making.
Reporting – General
May I report using either the Internet or the telephone?
Yes, with EthicsPoint, you may file a confidential, anonymous report via either the telephone or the Internet.
What type of things should I report?
The EthicsPoint system is designed for individuals to report issues or concerns related to potential violations of laws, regulations, policies and procedures (including the MJHS/Elderplan Code of Conduct) or any other concerns you may have. Other items may include requests for compliance guidance, questions or inquiries, or even suggestions.
If I see a violation, shouldn't I just report it to my manager or the Compliance Office and let them deal with it?
When you observe some behavior that you believe violates our Code of Conduct, we expect you to report it. Ideally, you should bring any concerns forward to your manager or the Compliance Office. We recognize, however, that there may be circumstances when you are not comfortable reporting an issue in this manner. It is for such circumstances that we have partnered with EthicsPoint. We would rather provide you with the option to report anonymously than keep the information to yourself.
Why should I report what I know? What’s in it for me?
We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner by informing the correct individuals if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the livelihood of an entire organization.
Does management really want me to report?
Yes, we certainly do. In fact, we need and encourage you to report. During the course of your workday, you could become aware of an activity that may be cause for concern. Reporting may assist us in minimizing the potential negative impact on MJHS/Elderplan and our community. Also, offering a suggestion may help us identify ways that we may improve our corporate culture and performance.
Where do these reports go? Who can access them?
Reports are entered directly on the EthicsPoint secure server to prevent any possible breach in security. EthicsPoint makes these reports available only to a very limited number of specific individuals within MJHS/Elderplan 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 focuses on being a positive aspect of our overall philosophy, and helps 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.
Reporting Security & Confidentiality
It is my understanding that any report I send from a MJHS/Elderplan computer generates a server log that shows every website with which my computer or mobile device connects. Won’t this log identify me as a report originator?
No. EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your computer or mobile device 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 computer or mobile device, you have the option of using a computer or mobile device outside our work environment (such as one located at an Internet café, at a friend’s house, etc.) through the EthicsPoint secure website. Many people choose this option.
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 completely maintained. Plus, EthicsPoint is contractually committed not to pursue a reporter’s identity.
I am concerned that the information I provide EthicsPoint will ultimately reveal my identity. How can you assure me that will not happen?
The EthicsPoint system is designed to protect your anonymity. However, if you wish to remain anonymous, you - as a reporting party – will need to ensure that the body of the report does not reveal your identity by accident. For example, you would not include something like, “From my cube next to Jan Smith…” or “In my 33 years…”. Please note that the report information is provided exactly as entered or spoken (depending on the manner of submission).
Is the telephone toll-free hotline confidential and anonymous too?
Yes. If you choose to phone in your report, you will be asked the same information that you would provide in an Internet-based report and an interviewer will type your responses into the EthicsPoint website. These reports have the same security and confidentiality measures applied to them during delivery. If you phone in your report, you may expect to spend 10 – 15 minutes on the phone with an EthicsPoint representative.
What if I want to be identified with my report?
There is a section in the report for identifying yourself, if you wish, regardless of reporting method.
Tips & Best Practices
I am aware of some individuals involved in unethical conduct, but this doesn't affect me. Why should I bother reporting it?
MJHS/Elderplan promotes ethical behavior. Unethical conduct, at any level, ultimately hurts MJHS/Elderplan and its employees, including you. You only have to consider what has happened in recent corporate scandals to see the disastrous effects that a seemingly harmless lapse in ethics may have on an otherwise healthy organization. So, if you know of any incidents of potential misconduct or ethical violations, it is your duty to report them.
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?
File a report. EthicsPoint can help you prepare and file your report so it may be reviewed. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you were unsure.
What if my boss or other managers are involved in a violation? Won’t they get the report and try to cover it up?
No, the EthicsPoint system and report distribution process 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 an incident after I file the report? Or what if additional information is needed from me concerning my report?
When you file a report through the EthicsPoint website or through the EthicsPoint Call Center, you will receive a unique report key and be asked to choose a password. You may return to the EthicsPoint system again either by Internet or telephone and access the original report in order to add more details or answer any questions that may posed as a follow up to the information you originally provided. We recommend that you return to the site in the time specified to provide such information. Should you receive such a request, the communication between you and MJHS/Elderplan will be exchanged via an “anonymous dialogue.”
When I respond to the follow-up or provide additional information, is this information treated in the same secure manner as the initial report submission?
All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.
Can I still file a report if I don’t have access to the Internet?
If you don’t have access to or are uncomfortable using a computer or mobile device, you may call the EthicsPoint toll-free hotline, which is available 24 hours a day, 365 days a year.
You may file an EthicsPoint report from any computer or mobile device that can access the Internet. You can file from home. Please note there are many public locations, including the public library, that have computers with Internet access.