A Message from the President

Dear Employees,

As President of Keystone Human Services, I am aware that the success of our agency depends on our people and how we conduct business. With integrity and in full compliance, each and every day we must earn the trust of the individuals that rely on us to provide what they need to participate in a meaningful life in their community. Stricter compliance requirements by funders, governments, and the international arena, and families and individuals themselves, mean that Keystone functions in a variety of very complex environments in which we must continually strive to provide the very best quality services possible.

Keystone’s Compliance and Integrity policies are designed to direct us to the best overall functioning in our environment, and Keystone’s Compliance Department, headed by Robyn Joppy, Keystone’s Vice President of Compliance, are here to assist the organization in assuring that we are doing our best. As employees however, we are all held to the highest level of personal responsibility to assure that our department, agency or subsidiary is not only in adherence with important compliance and integrity requirements, but that we, as an organization, continually exceed requirements with a constant focus on true needs of the individuals we serve.

I have always had a sense of pride in the quality of employees who work for Keystone, and am proud to be counted among you. Together, I’m certain that we continue to bring the highest level of integrity and passion to the work we do.

Sincerely,

Dennis W. Felty
President

Dear Fellow Employees,

As the Vice President of Corporate Compliance and Integrity and the Corporate Compliance Officer, I know our success not only depends on the quality and level of care we provide the individuals we support, the business relationships we establish and maintain, and the support and involvement of our local communities, but also on the trust and integrity that embodies our reputation.

Within Keystone, we have a great responsibility for the stewardship of the resources entrusted in our care, including working diligently to create services that are effective, accessible and affordable. Fiscal integrity is an essential quality of community and government supported services. Because of the importance of our work, we endeavor to assure all our constituencies have confidence in our financial system, business practices, contract compliance and knowledge of how resources are being utilized. Moreover, our constituencies can feel confident resources are applied in a manner that efficiently serves individuals and the community.

Consistent with our commitment to performing at the highest standard of ethical business conduct, we developed and implemented a Corporate Compliance and Integrity Plan that includes our Code of Conduct, and it is shared with all funders, business partners, officers, employees and Board members. The plan clearly identifies each person's obligation to make the best use of resources commended to us and to avoid and/or disclose all real and possible conflicts of interest. Although the majority of our Board members are volunteers, they are expected to comply with applicable laws and regulations in their dealings with and on behalf of Keystone, as well as hold the highest standards of integrity.

That being said, the Corporate Compliance and Integrity Department's Mission Statement communicates:

In continuation of our commitment to building an ethical culture, the Corporate Compliance and Integrity Department maintains an infrastructure of controls, systems and monitoring methods that enables Keystone Human Services to meet its responsibility for remaining in compliance with all applicable laws, statutes, regulatory requirements and internal policies and procedures.

Through promoting awareness, education, quality and transparency, we are dedicated to "doing the right thing" and encourage employee participation in an effort to achieve our goal of performing at the highest standard of ethical business conduct.

Keystone is committed to assuring all employees perform their job responsibilities with integrity, pride and excellence. Because compliance affects every employee, everyone is responsible for adhering to the policies and procedures that govern our business, by doing so ultimately supports our mission and vision.

Sincerely,

Robyn S. Joppy

Code of Conduct: What You Should Know About Keystone Human Services’ Code of Conduct	5
Roles of Keystone’s Compliance and Integrity Program	10
Principle 1: Legal Compliance	11
Standard 1.1—Antitrust	12
Standard 1.2—Tax	14
Standard 1.3—Fraud and Abuse	15
Standard 1.4—Lobbying/Political Activity	17
Standard 1.5—Environmental	19
Standard 1.6—Discrimination	20
Principle 2: Business Ethics	22
Standard 2.1—Honest Communication	23
Standard 2.2—Misappropriation of Proprietary Information	24
Standard 2.3—Employee/Vendor Screening	26
Principle 3: Confidentiality	27
Standard 3.1—Information Related to the People We Support	28
Standard 3.2—Proprietary Information	30
Standard 3.3—Personnel Actions/Decisions	32
Principle 4: Conflicts of Interest	33
Standard 4.1—Outside Financial Interests	34
Standard 4.2—Services for Competitors/Vendors	36
Standard 4.3—Participation on Boards of Directors/Trustees	38
Standard 4.4—Honorarium	40

Table of Contents (continued)

What You Should Know About
Keystone Human Services’
Code of Conduct

Why does Keystone have a Code of Conduct?

Keystone Human Services (collectively, “Keystone”) and its subsidiaries are fully committed to conducting business in compliance with the law and other acceptable standards of business conduct indicated in Keystone’s policies.

Businesses and organizations are under increasing pressure to adhere to appropriate legal and ethical standards. A failure to meet these standards can be harmful to Keystone, more importantly it would be wrong.

Keystone’s mission and value of human life further commands integrity and compliance with laws and standards from each and every one of our employees, Board members and volunteers.

As established by the Code of Conduct Policy, the purpose of this Code of Conduct is to provide standards by which employees of Keystone must conduct themselves in order to protect and promote organization-wide integrity and to enhance Keystone’s ability to achieve its mission. The Code of Conduct is designed to help each of us understand and follow the basic compliance and integrity rules applicable to our jobs and to know when and where to ask for advice.

Nothing in this Code of Conduct is intended to nor should be construed as providing any additional employment or contract rights to employees or other persons.

While Keystone will generally attempt to communicate changes concurrent with or prior to the implementation of such changes, Keystone reserves the right to modify, amend or alter the Code of Conduct without notice to any person or employee.

What is integrity?

Integrity is defined as the adherence to moral and ethical principles and having a sense of honesty. In other words, integrity is “doing the right thing even if nobody is watching.”

What You Should Know About
Keystone Human Services’
Code of Conduct (continued)

Who should follow the Code of Conduct?

Keystone expects all employees to abide by the following principles and standards and to conduct the business and affairs of Keystone in a manner consistent with the general statement of principles set forth herein.

Those employees who engage vendors, consultants and contractors must use reasonable efforts to monitor their work so that their actions are consistent with the Code of Conduct. Any concerns about vendors, consultants or contractors not doing business in accordance with the Code of Conduct should be referred to your supervisor and the Corporate Compliance Officer.

Additionally, we expect our Board members, volunteers and other contractors to comply with applicable laws and regulations in their dealings with and on behalf of Keystone, as well as hold the highest standards of integrity. As such, we share our Code of Conduct with them in order to relay our commitment to legal and ethical conduct.

What does this Code of Conduct have to do with me?

The Code of Conduct represents a commitment to do what is right. By working for Keystone, you are agreeing to uphold this commitment. You are expected to understand the standards set forth in this Code of Conduct and any policies that apply to your job—and more importantly you are expected to follow those standards and policies. Failure to abide by this Code of Conduct or the guidelines for behavior which the Code of Conduct represents may lead to disciplinary action. For alleged violations of the Code of Conduct, Keystone will weigh relevant facts and circumstances, including, but not limited to, the extent to which the behavior was contrary to the express language or general intent of the Code of Conduct, the egregiousness of the behavior, the employee’s history with Keystone and other factors that Keystone deems relevant. Discipline for failure to abide by the Code of Conduct may, at Keystone's discretion, range from progressive supervision up to and including termination.

How do I use this Code of Conduct?

The Code of Conduct contains principles articulating Keystone’s policy and standards that are intended to provide additional guidance. Commonly asked

What You Should Know About
Keystone Human Services’
Code of Conduct (continued)

Questions are provided as examples for each standard as are any applicable policies or sources for further information. All relevant policies and operational directives can be accessed through the Keystone Zone at www.keystonezone.com.

Is everything I need to know in the Code of Conduct?

While the Code of Conduct is a critical piece in Keystone’s commitment to integrity, it is not intended to describe every law or policy that may apply to you. You are responsible for identifying any additional rules that may be applicable to your subsidiary or position. For example:

Each Keystone subsidiary may have policies and procedures to further implement the standards in Keystone’s Code of Conduct. In cases where a subsidiary’s rules are stricter than those set forth in this Code of Conduct, you will be required to follow those stricter rules.
Depending on the location, i.e. state or country, where you work, additional laws may apply.

What about our subsidiaries outside of the United States?

Employees working for our subsidiaries overseas, i.e. Keystone Human Services International (KHSI), Keystone Human Services International Moldova Association (KHSIMA) and Keystone Foundation for Children and Families (KFCF) may be subject to the laws of the country in which they are located. While U.S. laws may still apply, you have an important responsibility to know and follow the local laws and standards as well as Keystone's internal policies and procedures.

Where do I fit into this?

All employees are responsible to ensure that their behavior and activity is consistent with the Code of Conduct. Keystone cannot live up to our ethical standards if our employees do not speak up or ask questions when they should. You play an essential part in compliance by reporting any known or suspected violations of the Code of Conduct, fraud and abuse, misuse of funds, and/or falsification of internal records to the Corporate Compliance Officer without fear of retaliation or job loss.

What You Should Know About
Keystone Human Services’
Code of Conduct (continued)

What about those who supervise others?

Keystone’s Executive Leadership and supervisors have additional responsibilities under the Code to:

Lead by example—show what it means to act with integrity;
Ensure that those they supervise have adequate knowledge, training and resources to follow the standards listed in the Code of Conduct;
Monitor the compliance of the people they supervise;
Enforce the standards of the Code of Conduct and all related company policies;
Support employees who in good faith raise questions or concerns about compliance and integrity issues. This means retaliation of any kind is not permitted; and
Report potential instances of non-compliance to the Corporate Compliance Officer.

Where do I go for help?

Should you have any questions about the Code of Conduct, or need further guidance, contact Keystone’s Corporate Compliance Officer.

Additionally, Keystone has provided 3 confidential help lines available for your use to report violations of the Code of Conduct:

You can CALL the Compliance Help Line at (717) 230-9702 or 1-888-857-5007.
You can report ONLINE at https://www.keystonehumanservices.org/compliance/compliance-referral-form.php.
You can SEND A LINE to:
Keystone Human Services
Attn: Corporate Compliance Officer
124 Pine Street
Harrisburg, PA 17101
(Mark the envelope CONFIDENTIAL)

To assist you when making your report, please review the Compliance Referral Form in the Appendix.

What You Should Know About
Keystone Human Services’
Code of Conduct (continued)

What happens when I use one of the Helplines?

Whether you call the helpline, complete an online referral or send a note directly to the Corporate Compliance Officer, someone from the Compliance and Integrity Department will respond to you in a timely manner. Depending on the nature of the concern or matter, the Compliance and Integrity Department will work with the appropriate departments, such as Human Resources or Executive Leadership, to investigate and resolve issues.

Should an investigation be deemed necessary, the Compliance and Integrity Department will look into the issue promptly and see that appropriate corrective action is taken as needed. For more information, view the Enforcement and Prevention Policy and corresponding Operational Directive for your service line.

Will I get into trouble for reporting?

Keystone Human Services does not tolerate retaliation toward any employee who in good faith seeks advice or reports a concern. Anyone who acts in retaliation toward an individual will be subject to disciplinary action, which may include termination. Keystone takes claims of retaliation very seriously. If you suspect that you or someone you know has been a victim of retaliation, immediately contact the Corporate Compliance Officer.

What if I don’t want to leave my name?

Keystone understands and respects your right to report compliance concerns anonymously. Should you choose to report anonymously, please provide enough information that your concerns can be thoroughly investigated. All reports, regardless of anonymity, will be kept confidential.

Roles of Keystone’s
Compliance and Integrity Program

The Code of Conduct is more than a description of our standards; it is the heart of Keystone's Compliance and Integrity Program.

The Compliance Program is administered by the Corporate Compliance Officer, who reviews the Compliance Program and company-wide adherence to the Code of Conduct with senior officers, the Compliance and Integrity Committee and the Keystone Human Services Board of Directors.

Together, the Compliance Officer, management team, and the Compliance and Integrity Committee have the responsibility of monitoring the Keystone Compliance and Integrity Program. This responsibility includes assuring:

Keystone employees comply with all applicable laws and regulations related to the services we provide;
Keystone and its employees act in accordance with appropriate ethical standards;
Keystone delivers high quality services to the individuals it serves;
Actual and potential risk areas are identified; and
The development of standards of conduct and policies and procedures is continued in order to promote compliance and integrity within Keystone.

As established in the Employee Compliance Education Policy, all employees will receive education on Keystone's Compliance and Integrity Plan and Code of Conduct, applicable laws, regulations, and policies. Depending on contract requirements, employees involved in the claim development and submission process will receive additional education, which may vary among subsidiaries. The compliance education relevant to your service line can be found in an Operational Directive under the Service Record Keeping Policy on the Keystone Zone, or is available from your Employee Development Director.

Principle 1
Legal Compliance

In all our business dealings, Keystone strives to be honest and fair. All activity by or on behalf of Keystone must be in compliance with applicable laws.

The following standards are intended to provide guidance to employees and assist them in their obligation to comply with applicable laws. These standards are neither exclusive nor complete. Employees are required to comply with all applicable laws, whether or not specifically addressed in these policies. If questions regarding the existence of, interpretation or application of any law arise, they should be directed to Keystone’s Corporate Compliance Officer.

“The right to do something does not mean that doing it is right.”
—William Safire

Standard 1.1—Antitrust

Keystone's subsidiaries strictly adhere to antitrust and unfair competition laws. Such laws prohibit anticompetitive agreements, such as price fixing and efforts to unfairly eliminate competitors. Employees are expected to seek advice from Keystone’s Corporate Compliance Officer when confronted with business decisions involving a risk of violation of the antitrust laws.

Conduct prohibited by antitrust laws:

Agreements to fix prices, bid rigging, collusion (including sharing of competitively sensitive information) with competitors
Boycotts, certain exclusive dealing and price discrimination agreements
Unfair trade practices including bribery, misappropriation of trade secrets, deception, intimidation and similar unfair practices.

Did you know . . .?

The penalties for price fixing are severe and can include prison sentences and large fines.
Even what may appear to be ordinary business contact, such as a lunch meeting with a competitor’s representative that includes a discussion of prohibited topics, can lead to claims of competition law violations.
Antitrust laws vary around the world. Many countries and individual states in the U.S. have laws prohibiting anticompetitive behavior. The laws that apply to you may vary depending on where you are located and where you conduct business. U.S. antitrust laws may still apply to you even if you are overseas.

Common Questions About Antitrust Laws

Q: One of the vendors we use is not as reliable as they once were. Can I recommend that we find a new vendor?

A: Yes. As long as a company isn’t making an agreement with competitors to boycott a particular vendor, it may stop doing business with the vendor if the company chooses.

Q: Can I tell a potential vendor how much we are currently paying for supplies and services so that they can submit a lower bid?

A: No. This would give the potential vendor an unfair advantage and would restrict competition.

Refer to Keystone’s Competitive Bidding Policy for further guidance.

Standard 1.2—Tax

As a tax-exempt entity, Keystone has a legal and ethical obligation to act in compliance with applicable laws, to engage in activities in furtherance of its charitable purpose, and to ensure that its resources are used in a manner that furthers the public good rather than private or personal interests of any individual. Consequently, Keystone and its employees will avoid compensation arrangements in excess of fair market value, will accurately report payments to appropriate taxing authorities, and will file all tax and information returns in a manner consistent with applicable laws.

“Relativity applies to physics, not ethics.”
—Albert Einstein

Standard 1.3—Fraud and Abuse

Keystone has an internal fraud and abuse audit program within the Corporate Compliance and Integrity Department. The Department investigates and reports any potential and real fraudulent activity. Fraudulent activity is that which is deliberately deceptive in order to secure unlawful or unfair gain. Keystone expects its employees to refrain from conduct that may violate the fraud and abuse laws.

Examples of conduct prohibited by fraud and abuse laws:

Direct, indirect or disguised payments in exchange for the referral of individuals
The submission of false, fraudulent or misleading claims to any government entity or third party payer, including claims for services not rendered, claims that characterize the service differently than the service actually rendered, or claims that do not otherwise comply with applicable program or contractual requirements
Making false representations to any person or entity in order to gain or retain participation in a program or to obtain payment for any service

Any employee who questions a billing practice or has questions on the legitimacy of a certain transaction should contact the Corporate Compliance and Integrity Department. The Corporate Compliance Officer will review all concerns and handle appropriately.

Common Questions About Fraud and Abuse Laws

Q: What is the difference between fraud and abuse?

A: Fraud occurs when someone knowingly makes a deception or misrepresentation of facts that results in or could potentially result in an unauthorized payment or benefit to the recipient. Abuse involves actions that are inconsistent with accepted, sound medical, business, or fiscal practices. Abuse can either directly or indirectly result in unnecessary costs to a funder through improper payments. Abusive actions are not committed knowingly or intentionally. While both activities have the same impact, the main difference is the individual’s intent.

Q: A funder requires that I provide 4 hours of service to an individual we support, but I only provided 3 hours. Should I still bill for 4 hours so we stay within the requirements of the contract?

A: No. Any claims characterizing a service different than what was actually rendered is in violation of fraud and abuse laws.

For further guidance, refer to Keystone’s Federal Deficit Reduction Act Compliance Policy and the Enforcement and Prevention Policy and corresponding Operational Directive specific to your service line.

Employees of Keystone Autism Services must also follow that subsidiary’s Adult Community Autism Program Compliance Policy.

Standard 1.4—Lobbying/Political Activity

The laws of the United States and certain other countries set strict limits on contributions by corporations to political parties and candidates, and violators are subject to severe penalties—including imprisonment and fines. Keystone expects each of its employees to refrain from engaging in activity that could jeopardize the tax exempt status of the organization, including a variety of lobbying and political activities.

Personal Political Activity

No individual may make any agreement to contribute any money, property, or services of any officer or employee at Keystone's expense to any political candidate, party, organization, committee or individual in violation of any applicable law. Keystone respects and supports employees who decide to participate in and contribute to political organizations or campaigns, but they must do so as individuals, not as representatives of Keystone, and they must use their own funds.

Organization Political Activity

Where its experience may be helpful, Keystone may publicly offer recommendations concerning legislation or regulations being considered. In addition, it may analyze and take public positions on issues that have a relationship to the operations of Keystone when its experience contributes to the understanding of such issues.

Lobbying

Keystone has many contacts and dealings with governmental bodies and officials. All such contacts and transactions must be conducted in an honest and ethical manner. Any attempt to influence the decision-making process of governmental bodies or officials by an improper offer of any benefit is absolutely prohibited. Any requests or demands by any governmental representative for any improper benefit should be immediately reported to the Corporate Compliance Officer.

Common Questions About Political Activity

Q: I help a local politician with his campaign. Can I use the office copier to make copies for mailings?

A: No. Company property and equipment may not be used for a political purpose.

Q: I would like to run for school board. Will this be a problem?

A: As long as your campaign activities are not taking place on Keystone time using Keystone equipment, you may do so. You should, however, inform your supervisor and the Corporate Compliance Officer to ensure that your running for school board does not cause a conflict of interest (see Standard 4.3).

For further guidance, refer to Keystone’s Prohibited Political Activity Policy.

Key Human Services, Inc. employees must also follow the Key Human Services Comprehensive Campaign Finance Reform Act Policy.

Standard 1.5—Environmental

Keystone expects full and complete compliance with all applicable environmental laws and regulations wherever we serve. We are committed to managing and operating our business in a manner that respects our environment and conserves natural resources. Employees will strive to utilize resources appropriately and efficiently, to recycle where possible and otherwise dispose of all waste in accordance with applicable laws and regulations, and to work cooperatively with the appropriate authorities to remedy any environmental contamination for which Keystone may be responsible. Every employee of Keystone is required to:

Conduct business in accordance with all applicable environmental laws, regulations, requirements and corporate commitments. In addition to legal compliance, this means acting consistently with environmental commitments and goals of your subsidiary.
Understand that the goal is to move toward environmentally sustainable practices where feasible—this means we must all know the environmental consequences of what we do, and look for ways to reduce or eliminate any negative consequences.
Follow specified procedures, notify management of potential environmental concerns, and share ideas for continuous performance improvement.

Common Question About Environmental Impact

Q: What can I do to make a difference to the impact Keystone has on the environment?

A: Even simple things like turning off lights, recycling paper, or using alternative forms of communication, such as teleconferencing and videoconferencing, to avoid unnecessary business travel can make a big difference.

Standard 1.6—Discrimination

Keystone is culturally diverse and believes that the fair and equitable treatment of employees, people we support and other persons is critical to fulfilling its vision and goals. Embracing that diversity, Keystone recruits, hires, promotes, disciplines and provides other conditions of employment without regard to a person's race, color or religion.

Similarly, Keystone is committed to treating the people we support without regard to the race, color, religion, sex, ethnic origin, age or disability of such person, or any other classification prohibited by law.

Having a professional work environment also means that Keystone will not tolerate any form of harassment. Harassment can be verbal, physical or visual behavior where the purpose or effect is to create an offensive, hostile or intimidating environment. Sexual harassment, in particular, can include sexual advances, requests for sexual favors, unwanted physical contact or repeated and unwelcome sexual suggestions. Other prohibited conduct includes: offensive racial, ethnic, religious, age-related, or sexual jokes or insults; distributing or displaying offensive pictures or cartoons; and using voicemail, e-mail or other electronic devices to transmit derogatory or discriminatory information. This kind of behavior has no place at Keystone.

“Action indeed is the sole medium of expression of ethics.”
—Jane Addams

Common Questions About Discrimination

Q: What if my religion does not tolerate the lifestyles of some individuals with whom I work?

A: By choosing to work for Keystone, you agreed to embrace diversity and not to discriminate against people. Speak with your supervisor about alternative program or job assignments.

Q: My supervisor often makes obscene jokes that I find offensive. I don’t feel comfortable approaching him about this. What can I do?

A: You can report your concerns confidentially using the Compliance Helpline, completing a web referral, or sending a note to the Corporate Compliance Officer. Although retaliation is against Keystone’s policies and will not be tolerated, you also have the right and the option to report anonymously. Additionally, you can report your concerns to Human Resources.

Refer to the following policies for additional guidance:

Harassment Policy
Non-Discrimination Equal Employment Opportunity Policy

Principle 2
Business Ethics

In furtherance of Keystone’s commitment to the highest standards of business ethics and integrity, employees must accurately and honestly represent Keystone and will not engage in any activity or scheme intended to defraud anyone of money, property or honest services.

The following standards are designed to provide guidance to ensure that its business activities reflect the high standards of business ethics and integrity. Employee conduct not specifically addressed by these standards must be consistent with Principle 2.

“It takes less time to do a thing right, than it does to explain why you did it wrong.”
—Henry Wadsworth Longfellow

Standard 2.1—Honest Communication

Keystone requires candor and honesty from individuals in the performance of their responsibilities and in communication with its attorneys and auditors. Employees may not make false or misleading statements to any individual whom we support or other person or entity doing business with Keystone about any individuals, persons or entities doing business or competing with Keystone, or about the products or services of Keystone or its competitors.

“If you tell the truth you don't have to remember anything.”
—Mark Twain

Standard 2.2—Misappropriation of Proprietary Information

Just as we protect our own confidential information (see Standard 3.2-Proprietary Information), employees are expected to respect the proprietary and confidential information of others. Such information can include written materials, software, music and other “intellectual property.” All of Keystone’s employees are responsible to ensure they do not improperly copy for their own use documents or computer programs in violation of applicable copyright laws or licensing agreements. All employees must comply with Keystone’s Information Security Policy.

Employees shall not utilize confidential business information obtained from competitors, including customer lists, price lists, contracts or other information in violation of a covenant not to compete, prior employment agreements, or in any other manner likely to provide an unfair competitive advantage to Keystone.

Did you know . . .?

Sharing copies of magazine articles with co-workers, e-mailing PDFs of articles, or inserting content into PowerPoint presentations may all require permission from the copyright holder.

Common Questions About the Misappropriation of Proprietary Information

Q: I used to work for one of Keystone’s competitors and have an extensive list of contacts and documents that could be useful to Keystone. May I use this information?

A: No. This information is proprietary information belonging to your previous employer and should not be used to give Keystone an unfair advantage.

Q: I have a computer program on my home computer that would be great to use for work. Since I already own the program can I just load it onto my work computer?

A: No. By loading the software onto your work computer you will be violating the licensing agreements that came with the software AND Keystone’s policies relating to Information Security.

Refer to the following policies for further guidance:

Technology Responsibility for Employees and Other Authorized Personnel Policy
Information Security Policy

Standard 2.3—Employee/Vendor Screening

In compliance with federal regulations, Keystone makes reasonable inquiry into the background of prospective employees and vendors whose job function or activities may impact the Medicare/Medicaid claim development and submission process, Keystone’s relationship with direct care personnel, or referral patterns between providers. These background screenings are required to ensure that Keystone is not hiring or contracting with any person or entity that has been convicted of a criminal offense related to health care or is listed by a federal agency as debarred, excluded or otherwise ineligible for federal program participation.

Refer to the Background Verification Policy and the Competitive Bidding Policy for more information.

Employees of Keystone Autism Services must also follow the Adult Community Autism Program Conflict of Interest Policy that is specific to that subsidiary.

Principle 3
Confidentiality

Keystone believes in respecting the confidentiality of our employees’ personal information as well as the information of the individuals we support. All employees must strive to maintain confidential information in accordance with applicable legal and ethical standards.

Keystone and its employees are in possession of and have access to a broad variety of confidential, sensitive and proprietary information, the inappropriate release of which could be injurious to the people we support, Keystone’s business partners and Keystone itself. Every employee of Keystone has an obligation to actively protect and safeguard confidential, sensitive and proprietary information in a manner designed to prevent the unauthorized disclosure of information. This means that access to personal records should be limited to company personnel who have appropriate authorization and a clear business need for that information. Employees who have access to personal information must treat it appropriately and confidentially.

“To know what is right and to not do it is the worst cowardice.”
—Confucius

Standard 3.1—Information Related to the
People We Support

Every Keystone employee has an obligation to conduct themselves in accordance with the principle of maintaining the confidentiality of information from and about people we support in accordance with all applicable laws and regulations. Employees must refrain from sharing any personal or confidential information unless in conformity with applicable local, state, federal and/or international laws and Keystone’s internal policies and procedures.

In the United States, the Department of Health and Human Services (HHS) has issued a set of national standards for the protection of health information under the Privacy Rule. The Privacy Rule standards address the use and disclosure of Protected Health Information (PHI) as well as standards for an individual’s privacy rights and their right to control how their health information is used. The Office for Civil Rights has the responsibility for implementing and enforcing the Health Insurance Portability and Accountability Act (HIPAA) Privacy regulations.

Privacy laws in other countries may differ from those of the United States. Keystone recognizes and complies with standards enforced to protect individually identifiable information for individuals we serve in each country where we conduct business. These standards are utilized to address the use and disclosure of protected health information as well as the maintenance and security of transmitted health information. Keystone believes and recognizes every individual we support has a right to privacy and to the protection of their health information. Employees operating overseas must be aware of the privacy laws of the country and locality in which they work and follow them accordingly.

All employees are educated about confidentiality and privacy regulations prior to being responsible for protected health information and have an obligation to follow all applicable confidentiality and privacy policies and procedures. These policies and procedures are related to privacy and confidentiality, individual access and disclosure of protected health information and communication preferences.

If questions arise regarding an obligation to maintain the confidentiality of information or the appropriateness of releasing information, employees should seek guidance from management or Keystone's Corporate Compliance Officer. Employees should contact management or their Privacy Officer if they have questions about specific privacy and confidentiality or HIPAA-related policies or procedures.

Common Questions About Information Related to the People We Support

Q: I saw the friend of an individual we support at the grocery store. He asked me about the individual’s medical condition and her treatment plan. Since I know him to be a friend of the individual, can I tell him the information?

A: No. That information is considered protected health information and must not be disclosed to or discussed with anyone who does not have authorization to obtain that information.

Q: I occasionally work from home. Can I e-mail documents that contain protected health information to my home computer?

A: No. You should never use your home computer to open or work on documents containing an individual’s protected health information. Your home computer is not secure and the information could be accessed by third parties resulting in a breach.

For more information, refer to Keystone’s policies regarding HIPAA and the confidentiality of the people we support, which can be found on Keystone Zone.

Also refer to the Technology Responsibilities for Employees and Other Authorized Personnel Policy.

Standard 3.2—Proprietary Information

Keystone’s information, ideas and intellectual property assets are important to organizational success. Information pertaining to Keystone’s competitive position or business strategies, payment and reimbursement information, and information relating to negotiations with employees or third parties should be protected and shared only with employees having a need to know such information in order to perform their job responsibilities. Employees should exercise care to ensure that intellectual property rights, including patents, trademarks, copyrights and software, are carefully maintained and managed to preserve and protect its value. Additionally, any records created as part of your work for Keystone become company property and are not part of your personal records.

Common Question About Proprietary Information

Q: I would like to share how Keystone bills its services with a friend of mine who works for an organization in another state that is similar to Keystone and is not a competitor of Keystone. Is this permissible?

A: No. Regardless if the person or organization is in another state and not a competitor, that information is proprietary and should not be shared with outside sources or with people who do not have a need to know.

Refer to Keystone’s Employee Conflict of Interest Policy for more about protecting proprietary information.

Standard 3.3—Personnel Actions/Decisions

Keystone respects its employees’ information. Access to personal records, including salary, benefit and other personal information relating to employees, should be limited to personnel who have appropriate authorization and a clear business need for that information. Those employees having access to such information should treat it as confidential. As such, personal employee information should never be provided to anyone outside of Keystone without proper authorization.

Common Question About Personnel Actions/Decisions

Q: My supervisor told me about another employee’s performance review, but I don’t think that disclosure was appropriate. Should I report him to someone?

A: Yes. All employee information should be protected and only shared with people on a need-to-know basis. You should report the incident to the Corporate Compliance Officer or to Human Resources.

Refer to Keystone’s Confidentiality of Employee Personnel Records Policy for further guidance.

Principle 4
Conflicts of Interest

As employees of Keystone Human Services, we work together to meet our common goals. With loyalty and objectivity, we make decisions that affect the company based on the company’s best interest—independent of personal or other outside influences. We must never use our positions to profit personally or to assist others in profiting in any way at the expense of the organization.

Keystone recognizes that our employees are involved in many activities outside of their work with the company. A conflict of interest arises when an employee’s personal, social, or other activities or relationships have the potential to interfere with the employee’s loyalty to Keystone or objectivity in doing business. Your obligation to conduct company business in an honest and ethical manner includes the appropriate handling of actual and apparent conflicts of interest. This sometimes requires that conflicts be avoided altogether, and it always requires full disclosure of any actual or apparent conflicts of interest.

Note: Board members are responsible for adhering to Keystone's Conflict of Interest for Officers and Directors Policy.

“What is right is often forgotten by what is convenient.”
—Bodie Thoen, 'Warsaw Requiem'

Standard 4.1—Outside Financial Interests

While not all-inclusive, the following will serve as a guide to the types of activities by an employee, or household member of an employee that might cause conflicts of interest:

Ownership in or employment by an outside company that does business with Keystone. This does not apply to stock or other investments held in a publicly held corporation, provided the value of the stock or other investments does not exceed 5% of the corporation’s stock. Keystone may, following a review of the relevant facts, permit ownership interests that exceed these amounts if management concludes such ownership interests will not adversely impact Keystone’s business interest or the judgment of the employee.
Representation of Keystone by an employee in any transaction in which he or she or a household member has a substantial personal interest.
Disclosure or use of confidential, special or inside information of or about Keystone, particularly for personal profit or advantage of the employee or a household member.
Competition with Keystone by an employee, directly or indirectly or in the purchase, sale or ownership of property or property rights or interests, or business or investment opportunities.

“Have the courage to say no. Have the courage to face the truth. Do the right thing because it is right. These are the magic keys to living your life with integrity.”
—W. Clement Stone

Common Question About Outside Financial Interests

Q: My husband is a general contractor. Since I handle the hiring of contractors for my agency, wouldn’t it be easier to just have my husband do some of the various repairs around the building?

A: Because your husband is a household member, you would have a personal interest in his doing work for Keystone. Your involvement in contracting with him would be highly inappropriate.

For more information, refer to the Employee Conflict of Interest Policy and the Conflict of Interest for Directors and Officers Policy.

Standard 4.2—Services for Competitors/Vendors

Employment for or doing any sort of business with a current or potential vendor, business partner or competitor of Keystone could create a conflict of interest. While not all situations cause a conflict, you must obtain the approval of your supervisor before taking on a position with such an organization.

Additionally, employees may not be directors, officers or consultants of a current or potential vendor, business partner or competitor, nor permit his or her name to be used in any fashion that would suggest a business connection with that particular organization without appropriate authorization.

“The reputation of a thousand years may be determined by the conduct of one hour.”
—Japanese Proverb

Common Question About Services for Competitors/Vendors

Q: I work part time at an agency that is very similar to Keystone, but I am not sure if they are a competitor. What should I do?

A: You should talk to your supervisor and the Corporate Compliance Officer to find out if this will raise a conflict of interest. Also, you should report this information in the Annual Disclosure Statement.

Refer to Keystone’s Conflict of Interest Policy for further guidance.

Standard 4.3—Participation on Boards of Directors/Trustees

Occasionally, an employee may be asked to serve on the board of directors, an advisory board or a committee for a profit or non-profit organization. This can, in some cases, raise a real or apparent conflict of interest or even a legal issue.

An employee must obtain approval from his/her supervisor prior to serving as a member of the board of directors/trustees of any organization whose interests may conflict with Keystone’s.
An employee who is asked, or seeks to serve on the board of directors/trustees of any organization whose interest would not impact Keystone (for example, civic, most charitable, fraternal, etc.) will not be required to obtain such approval.
All fees/compensation (other than reimbursement for expenses arising from board participation) that are received for board services provided during normal work time shall be paid directly to Keystone (unless the employee uses paid time off to attend the meeting).
An employee must disclose all board of directors/trustees activities in the Annual Disclosure Statement.
Keystone retains the right to prohibit membership on any board of directors/trustees where such membership might conflict with Keystone’s best interests.
Questions regarding whether or not board participation might present a conflict of interest should be discussed with your supervisor.

Common Question About Participation on Boards of Directors/Trustees

Q: I have been a long-time volunteer for a local charity whose mission and work is very different from that of Keystone’s. They asked me to serve on their Board of Directors. Is this permissible?

A: Since the organization’s interests would not be in conflict with or impact Keystone, there should not be an issue with you serving on the board. However, you should still disclose that you are serving on the board in the Annual Disclosure Statement.

Standard 4.4—Honorarium

Employees are, with the permission of their supervisor, encouraged to participate as faculty and speakers at education programs and functions. However, any honorarium received by an employee must be turned over to Keystone unless the employee used paid time off to attend the program or that portion of the program for which the honorarium is paid.

Common Question About Honorarium

Q: I participated in a program at my alma mater during which I gave a talk about serving certain members of our community. My participation was on company time since it was relevant to what we do at Keystone. The school gave me an honorarium of $100.00 for my part in the program. What should I do with the money?

A: Since you participated in the program on Keystone’s time, the money will have to be turned over to Keystone for use by Keystone.

“We judge ourselves by what we feel capable of doing, while others judge us by what we have already done.”
—Henry Wadsworth Longfellow, 'Kavanagh'

Principle 5
Business Relationships

Business transactions with vendors, contractors and other third parties must be done so free from offers or solicitation of gifts and favors or other improper inducements in exchange for influence or assistance in a transaction.

The following standards are intended to guide employees in determining the appropriateness of the listed activities or behaviors within the context of Keystone’s business relationships, including relationships with vendors, providers, contractors, third party payers and government entities. It is the intent of Keystone that this policy be construed broadly to avoid even the appearance of improper activity. If there is any doubt or concern about whether specific conduct or activities are ethical or otherwise appropriate, you should contact Keystone’s Corporate Compliance Officer.

“Every job is a self-portrait of the person who does it. Autograph your work with excellence.”
—Unknown

Standard 5.1—Gifts and Gratuities

Keystone has many suppliers, vendors, contractors and consultants, and all are vital to our companies’ success. That is why business relationships with third parties with which we do business must be based solely on sound business decisions and fair dealing. Business gifts and entertainment can build good will, but they can also make it harder to be objective about the person providing them. In short, gifts and entertainment can create their own conflicts of interest.

Keystone’s employees may not seek to gain any advantage through the improper use of payments, business courtesies or other inducements. Offering, giving, soliciting or receiving any form of bribe or other improper payment is prohibited as this would be considered a business inducement.

Gifts, which includes entertainment and gratuities, may be anything of value, such as discounts, cash, loans, favorable terms on any product or service, services, prizes, transportation, use of vehicles or vacation facilities, stocks or other securities, participation in stock offering, home improvements, tickets to events and gift certificates.

Note: In some of Keystone's subsidiaries, i.e. KHSI, KHSIMA and KFCF, or functions (i.e. consultants traveling overseas on behalf of Keystone), more restrictive standards on gifts and gratuities may apply. Employees of those subsidiaries or functions must not accept any gift or gratuity that violates those standards.

Standard 5.1—Gifts and Gratuities (continued)

Gifts and gratuities offered to Keystone Employees fall into the following categories:

Usually OK

Some gifts and gratuities are small enough that they do not require approval; however, they must be reported in the Annual Disclosure Statement (ADS).

Occasional meals with a business associate.
Attendance at local, vendor-sponsored workshops, seminars and training sessions. Attendance at vendor expense at out of town seminars, workshops and training sessions is permitted only with the approval of the employee’s supervisor.
Employees may accept small gifts/gratuities from people we support or their family members during the holidays, however they cannot be solicited. Examples include: box of candy, fruit basket, gift certificate for $25.00 or less.
Ordinary sports, theater and cultural events. In most circumstances, a regular representative of the vendor should be in attendance with the employee.
Appropriate commissions, rebates, discounts and allowances with the approval of an employee’s supervisor, and provided that they do not constitute illegal or unethical payments.
Other reasonable and customary gifts, entertainment and/or gratuities.

Similarly, accepting promotional items of nominal value (no more than $25.00), such as pens, calendars and coffee mugs from a vendor that are given to customers in general, does not require approval, but requires disclosure in the ADS. Keystone expects employees to exercise good judgment and discretion in accepting gifts. If there is a concern whether a gift should be accepted, please consult your supervisor or the Corporate Compliance Officer. To the extent possible, these gifts should be shared with co-workers.

In addition, employees may provide gifts, entertainment and meals of nominal value to individuals we support, current and prospective business partners and other persons when such activities have a legitimate business purpose and are reasonable and consistent with all applicable laws.

Standard 5.1—Gifts and Gratuities (continued)

Always Wrong

Other types of gifts and gratuities are simply wrong, either in fact or in appearance, so they are never permissible, and they will not be approved. Employees may never:

Accept any gift or gratuity that would be illegal or in any violation of law.
Accept any gift of cash or cash equivalent (such as gift certificates that are transferrable or convertible into cash), bank check, money order, investment securities, loans, stock, or stock options.
Accept or request anything as a quid pro quo (offered for something in return), or as part of an agreement to do anything in return for the gift or gratuity.
Participate in any entertainment that is unsavory, sexually oriented or otherwise violates our commitment to integrity, trust and respect.
Solicit tips, personal gratuities or gifts from people we support and their family members, and from accepting monetary tips or gratuities. If a person we support or other individual wishes to present a monetary gift, he/she should be referred to the CEO of Keystone Partnership.
Accept gifts, favors, services, gratuities, entertainment or other things of value to the extent that decision-making or actions affecting the organization might be influenced. Similarly, the offer or giving of money, services, or other things of value with the expectation of influencing the judgment or decision-making process of any purchaser, supplier, customer, government official or other person by the organization is absolutely prohibited. Any such conduct must be reported immediately to your supervisor and/or the Corporate Compliance Officer.

Standard 5.1—Gifts and Gratuities (continued)

Always Ask

For anything that does not fit into the other categories, it may or may not be permissible to proceed; you will need to get written approval from your supervisor and the Corporate Compliance Officer. Examples in this category include the following, when paid by a current or potential supplier, vendor or consultant:

Special events—such as World Series, Super Bowl game, or NBA Finals (these usually have high dollar values).
Travel or entertainment lasting more than a day.

In determining whether to approve something in the “Always Ask” category, supervisors and the Corporate Compliance Officer will use reasonable judgment and consider issues as:

Whether the gift or gratuity would be likely to influence your objectivity.
Whether there is a business purpose (for example, business will be discussed as part of the event in question).
What kind of precedent it would set for other employees.
How it would appear to other employees, the people we support, their family members, our constituencies and the community-at-large.

Note: Nothing in this policy shall prohibit a business unit or supervisor from establishing stricter rules relating to the acceptance of gifts, gratuities, or other things of value from vendors.

Standard 5.1—Gifts and Gratuities (continued)

Other Considerations on Gifts and Gratuities:

Notifying Suppliers, Vendors, Contractors and Consultants:: You should inform all persons with whom you are doing or seeking to do business of this policy.
What to Do if You Receive an Impermissible Gift:: You must immediately return any gift of cash or cash equivalent such as gift certificates that are transferrable or convertible into cash, bank check, money order, investment securities, negotiable instrument (i.e. promissory notes and certificates of deposit), loans, stock or stock options. For other types of gifts over the “Usually OK” amount, if the Corporate Compliance Officer determines that returning the gift is impractical or undesirable, you should turn the gifts over the Corporate Compliance Officer for company use, sale or donation. Gifts such as a picture desk set or the like may be used in your company office with the written permission of the Corporate Compliance Officer or according to established procedures at your company, but will remain company property. If appropriate, a letter should be sent to the donor explaining the policy with respect to gifts.
Gifts to Government Officials or Employees:: Gifts and entertainment offered or provided to government officials and government employees directly or indirectly raise special risks. Never offer or provide any gift, entertainment or anything of value to a government official or employee that is illegal or that would cause the official or employee to violate established ethics or other rules governing his or her conduct.

Common Questions About Gifts and Gratuities

Q: The mother of someone we support would like to give me $100.00 to show appreciation for my work. Am I allowed to accept the money?

A: No. Employees should not accept or receive any money or other item of value greater than $25.00 (or less as defined by your subsidiary), whether intended to be for Keystone or for the personal benefit of the employee. You should politely let the family member know that it would be against Keystone's policy to accept the money. Remember, any gift you do receive must be reported in the Annual Disclosure Statement.

Q: A vendor we have used for a long time would like to take me to lunch for their “Customer Appreciation” week. Will this cause a problem?

A: Since the vendor does not regularly offer to buy you meals and it is simply a gesture of good will, it would be permissible for you to attend the lunch with him. However, you still must report the lunch in the Annual Disclosure Statement.

For more information, refer to the Employee Conflict of Interest Policy and the Professionalism Policy.

Standard 5.2—Contracting

Employees may not utilize “insider” information for any business activity conducted by or on behalf of Keystone. All business relations with contractors must be conducted at arm’s length both in fact and in appearance and in compliance with Keystone’s policies and procedures. Employees must disclose personal relationships and business activities with contractor personnel that may be construed by an impartial observer as influencing the employees’ performance or duties. Employees have a responsibility to obtain clarification from management on questionable issues that may arise and to comply, where applicable, with Keystone’s Conflict of Interest Policy.

Common Question About Contracting

Q: I overheard someone mention that we will no longer be using a particular contractor. I know someone who would be great! Can I give him a “heads up” that he can put in a bid soon?

A: No. This is considered insider information and should not be disclosed. Further, your relationship with the contractor could be a potential conflict of interest.

Standard 5.3—International Bribery

Because Keystone has an overseas presence, we must abide by the laws of other countries as well as U.S. laws applicable outside of the United States. In many of Keystone’s functions, employees work with foreign officials and it is especially important that these dealings be appropriate and free from corruption. When dealing with foreign officials, including government employees and consultants, Keystone employees must follow the guidelines detailed in the Foreign Corrupt Practices Act.

Foreign Corrupt Practices Act

The Foreign Corrupt Practices Act (FCPA) applies to all Keystone subsidiaries, employees, agents and representatives worldwide. The FCPA prohibits bribes or other unlawful payments made to government officials in order to gain an improper advantage. Violating the FCPA is a criminal offense and results in serious penalties for the company and the individual(s) involved in the bribe. Penalties for violating the FCPA can include fines, loss of business privileges and imprisonment.

The FCPA further requires that payments are honestly described and not used for unlawful purposes. Accordingly, Keystone has developed and continues to maintain a system of accounting controls that assure an accurate detail of books and records.

Activities Violating the FCPA include:

The offering or giving of anything of value to a government official for the purpose of obtaining or retaining business, or for any improper purpose including payments to reduce taxes and customs duties.
Making improper payments through third parties. When selecting agents and partners, subsidiaries must take extra care, especially if the prospective agent is a government official or in association with a government official.

Steps to Avoid Prohibited Actions:

Never make an unauthorized payment or authorize an improper payment or gift, either directly or through an agent, to a government official.

Standard 5.3—International Bribery (continued)

Never induce a government official or anyone else to do something illegal.
Never establish an unrecorded fund for any purpose.
Never make false or misleading entries in Keystone’s books.
Always report any indication of improper payments, gifts or entertainment.
Never induce someone else to violate these rules, or ignore a potential violation.

Facilitating or “Grease” Payments

Facilitating payments, also known as “grease” payments, are made in order to expedite or to secure the performance of routine governmental action, including obtaining permits and licenses, and providing phone service, power and water supply, etc. While facilitating or “grease” payments may not be illegal under the FCPA, they may violate local law or other federal statutes. While Keystone discourages such payments, a payment may only be made if all of the following conditions are met:

You obtain approval from the Corporate Compliance Officer.
It is legal in the country in question.
It is necessary to obtain or expedite legitimate, customary duties.
It is requested by the government official.
The payment is fully and accurately recorded in Keystone’s books.
It does not relate to a decision to award business to, or to continue doing business with the company.

Common Questions About International Bribery

Q: I was told by a foreign government official that it may take several months to obtain a permit for a new project our subsidiary is developing. He said if I want to move things along quicker all I need to do is pay extra for the permit and he would see it through. I want to get the project started. What should I do?

A: The Foreign Corrupt Practices Act does not forbid facilitating or “grease” payments in order to expedite or secure routine governmental action. However, these payments could be in violation of other federal or local laws. You should check with the Corporate Compliance Officer prior to giving any money to the government official.

Q: Our overseas contract is up for renewal. My colleagues and I invited the government officials that handle contract renewal to join us in attending a lavish dinner and entertainment next month in Monte Carlo. Is this an appropriate business practice?

A: No. Never offer or give anything of value to a government official for the purpose of obtaining or retaining business.

Refer to Keystone’s Foreign Corrupt Practices Act Policy for further guidance.

Principle 6
Protection of Assets

The employees of Keystone seek to achieve fiscal integrity and transparency by working hard to attain superior financial results. In pursuing this goal, each subsidiary and its employees will produce honest, accurate, timely reports and records, will protect company assets and resources and will never engage in fraud. In other words, fraud of any kind will not be tolerated.

All employees will strive to preserve and protect Keystone’s assets by making prudent and effective use of its resources and properly and accurately reporting its financial condition.

In today’s world, an organization’s credibility is judged in many fashions: one very important way is the accuracy and integrity of its books and records. Keystone is committed to providing stakeholders with complete, accurate, timely and understandable information, in all material respects, about the company’s financial condition and results of operations. In meeting this commitment, Keystone assures fiscal oversight via the Finance , Investment, and Audit Committees in addition to engaging external auditors.

Keystone’s obligation includes more than financial information. Every employee of Keystone must help ensure that reporting of any business information of whatever kind (financial or otherwise) and in whatever form (computerized, paper, etc.) is accurate, complete and timely. This includes, among other things, accurately recording time sheets, expense reports, costs, billing, documentation, vouchers, regulatory data, etc. No employee should say or write anything about a transaction that would cause anyone to prepare a false or misleading financial statement, report, bill, etc.

All employees of Keystone must:

Follow all laws, accounting requirements and company policies and procedures for reporting finances and other business information.
Never deliberately make a false or misleading entry in a report or record.
Never alter or destroy company records except as authorized by established policies and procedures.
Cooperate with internal and external auditors (see the External Auditing Policy for additional guidelines to follow when preparing for and responding to an external audit notice).

Standard 6.1—Internal Control

Keystone has established control standards and procedures to ensure that assets are protected and properly used and that financial records and reports are accurate and reliable. Internal control is the process by which the Board of Directors and management obtain assurance that company goals and objectives are being achieved and that the individual components and activities of the business are performed as expected.

To ensure accuracy of our books and records and our compliance with legal, regulatory and contract requirements, Keystone's Corporate Compliance and Integrity Department conducts internal audits. Keystone receives funding from various sources, for example the Department of Public Welfare in Pennsylvania and the Department of Developmental Services in Connecticut. Through internal audits, we have developed a procedure to ensure our funders are properly reimbursed when applicable and their funds are not being wasted. How audits are conducted may differ between subsidiaries. Refer to the Service Record Keeping Policy and corresponding Operational Directive that applies to your subsidiary or service line for more information. At times, the Corporate Compliance and Integrity Department may engage a consultant to assist with the internal auditing process.

Additionally, internal controls will provide assurance that financial and operating data and reports are accurate, complete and reliable. The Corporate Compliance and Integrity Department will work in conjunction with Finance and Operations to ensure that we are in compliance with applicable legal and regulatory requirements and that our controls are proper.

The function of the Corporate Compliance and Integrity Department’s oversight of the internal control process is critical to the success of Keystone. Accordingly, full cooperation and complete, timely and accurate disclosure of information to the Corporate Compliance and Integrity Department upon request is essential. Any Keystone employee who impairs, impedes or hinders in any way an internal audit may be subject to discipline, including without limitation, suspension or termination.

Standard 6.2—Financial Reporting

Every employee is responsible for ensuring that all financial reports, accounting records, research reports, expense accounts, timesheets and other documents are accurate and clearly represent the relevant facts or the true nature of a transaction. Employees should never make false or misleading entries in reports or other records. Fraudulent accounting or documentation is contrary to Keystone’s policies and may be in violation of applicable laws.

Some of Keystone's funders, for example Medical Assistance, may require additional documentation to support an invoice. Employees of the subsidiaries that those requirements apply must follow the relevant policies and standards when billing the funder.

Further, employees should never alter or destroy company records except as authorized by established policies and procedures.

Fraud of any kind will NOT be tolerated by Keystone.

“In times like these men should utter nothing for which they would not be willingly responsible through time and in eternity.”
—Abraham Lincoln

Common Question About Financial Reporting

Q: My supervisor told me to delay submitting an invoice so our department doesn’t go over budget for the current fiscal year. What should I do?

A: The invoice should be paid in accordance with the payment terms agreed with the vendor. Payments should never be delayed as an effort to keep within departmental budgets.

Refer to the Time Records Policy, the Record Retention Policy, and the Service Record Keeping Policy and corresponding Operational Directives for further guidance.

Employees of KEY are also required to follow the Attendance/Visit Sheets Operational Directive under the Service Record Keeping Policy.

Standard 6.3—Travel and Entertainment

Employees should be mindful that travel and entertainment expenses should be consistent with the employee’s job responsibility and Keystone’s needs and resources. It is Keystone’s policy that an employee should not suffer a financial loss or a financial gain as a result of business travel and entertainment. Employees are expected to exercise reasonable judgment in the use of company funds (including cash and cash equivalents, checks, purchasing cards, postage, reimbursements, etc.) and to spend Keystone’s funds as carefully as they would spend their own.

Common Question About Travel and Entertainment

Q: One of my co-workers always “pads” her mileage reports so she will be reimbursed more money. When I approached her about it she said that a little extra doesn’t hurt and our supervisor doesn’t care. What should I do?

A: You should report her and your supervisor to the Corporate Compliance Officer. Similar to Standard 6.2, all employees are expected to provide accurate mileage records and no employee should make a financial profit from regular business travel.

Refer to the Employee Incurred Expenses and Reimbursements Policy for further guidance.

Standard 6.4—Personal Use of Keystone’s Assets

All employees are responsible for using good judgment so that Keystone’s assets are not misused or wasted. All property and business of Keystone shall be conducted in a manner designed to further Keystone’s interest rather than the personal interest of an individual employee.

Keystone’s telephone, e-mail and voicemail systems are provided to employees for Keystone business purposes. Employees should refrain from using these systems in a manner that could be harmful or embarrassing to the company.

An employee should obtain approval from his or her supervisor before engaging in any personal or non-work related activity on company time that will result in remuneration to the employee or the use of company equipment, supplies, etc.

“You can't, in sound morals, condemn a man for taking care of his own integrity. It is his clear duty.”
—Joseph Conrad

Common Question About the Personal Use of Keystone’s Assets

Q: My daughter’s school sometimes sends me important information to my work e-mail. Is this a problem?

A: Keystone’s e-mail system is provided for business purposes. The occasional use for personal reasons is permissible as long as the personal use does not interfere with normal business activities and the nature of the use is not inappropriate or embarrassing to Keystone.

Refer to the Use of KHS Equipment Policy and the Electronic Mail Policy for more information.

Compliance Referral Form

Date: _________________

Reporter’s Information:

As the person making this referral to the Corporate Compliance & Integrity Department it is important that we are able to contact you should we need additional information regarding this report. All information is held in strict confidence. Please complete the following information as it pertains to you the reporter.

Anonymous May we contact you for additional information? Yes or No

Name: __________________________ Title/Relationship: _____________________

Address: _________________________________ City: ______________________

State: ______________ Zip: _______________

Phone: _______________ Other Phone: ______________
E-mail Address: _________________

Agency: _______________ Program: __________________
Program (Other): ______________

Referral/Incident Information:

The information below pertains to the reason for your referral. Please report who/what this referral is about; an individual receiving services, an employee, situation, incident, etc.

Reason for Referral:

Complaint
(to express dissatisfaction)

Consultative
(to ask for an opinion)

Informational
(to give facts or opinions)

Individual/Issue Being Reported:

Employee Individual Receiving Services
Other (please list)_____________________

Name:____________________________ Title:__________________________

Agency: _________________________ Program: _______________________

Other:___________________________ County:_________________________

(over)

Compliance Referral Form (continued)

Date of Incident: _____________ Time:___________ AM/PM ______

Location: ________________________________________________________

Incident Affected: (check all that apply)

Self Employee Individual Receiving Services
Other (please list)__________________________________

Incident Description:

_________________________________________________________________

Index

A
Antitrust	12
Assets,
Personal Use of	57
Protection of	52
Attorneys	23
Audit,
Preparing for	53
Auditors	23
B
Board membership	38
Bribery	12,49-50
Boycotts	12
Business Ethics	22-26
Business Inducements	41-42
Business Relationships	41-51
C
Campaign	17-18
Code of Conduct,
About	5-9
Competitors	12,23-24,36
Competitive bidding	13
Compliance and Integrity Program	10
Compliance Help Lines	8-9
Collusion	12
Confidentiality	27-32
Conflicts of Interest	33-40
Contractors	6,35,41-42,46,48
Contracting	48
Copyright	24,30
D
Discrimination	20
E
E-mail	20,24,29,57-58
Employee/Vendor Screening	26
Entertainment	42-50,56

Environment	19
Equipment	57
F
Facilitating payments	50-51
Financial Reporting	54-55
Foreign Corrupt Practices Act	49-51
Fraud and Abuse	7,15-16
G
Gift certificates	43-44
Gifts	42-50
from family members	43-44,47
from people we support	43-44
notifying others of gifts policy	46
to business partners	43
to people we support	43
Government Officials,
Dealings with	17
Gifts to	46
Payments to	49
Gratuities	42-50
Grease payments	50-51
H
Harassment	20-21
Health Insurance Portability and Accountability Act (HIPAA)	28
Honest Communication	23
Honorarium	40
I
Impermissible gifts	44,46
Information Related to the People We Support	28
Integrity,
Definition of	5
Intellectual property	24,30
Internal Control	53
International Bribery	49-51

Index

J
Jokes	20-21
K
Keystone’s equipment
use of	57
Keystone’s policies	6-7
L
Legal Compliance	11-21
Lobbying	17
M
Meals	43,47
N
NBA Finals	45
Nominal value	43
O
Outside Financial Interests	34-35
Outside employment	34
P
Personal information	27,32
Personnel Actions/Decisions	32
Policies	6-7
Political activity	17-18
Price fixing	12
Privacy Officer	28
Privacy Rule	28
Proprietary information	24-25,27,30-31
Protected Health Information (PHI)	28
Protection of Assets	52
Purpose of the Code of Conduct	5

R
Records,
Access to	27,32
Creation of	30
Destruction of	54
Financial	52-55
Religion,
discrimination against	20
Reporting Violations	7,9-10
S
Seminars	43
Services for Competitors/Vendors	36-37
Sexual Harassment	20
Special events	45
Stock	34,42,44,46
Super Bowl	45
T
Tax	14
Telephone	57
Tickets	45
Timesheets	54
Travel	19,45,56
Training sessions	43
Trustees	38-39
V
Vendors	6,26,36-37,41-42,45-46
Voicemail	57
W
Where to Go For Help	8
Workshops	43
World Series	45

Principle 5: Business Relationships	41
Standard 5.1—Gifts and Gratuities	42
Standard 5.2—Contracting	48
Standard 5.3—International Bribery	49
Principle 6: Protection of Assets	52
Standard 6.1—Internal Control	53
Standard 6.2—Financial Reporting	54
Standard 6.3—Travel and Entertainment	56
Standard 6.4—Personal Use of Keystone’s Assets	57
Appendix:
Compliance Referral Form	i
Index	iii

A Message from the President

Table of Contents

Table of Contents (continued)

What You Should Know About Keystone Human Services’ Code of Conduct

Why does Keystone have a Code of Conduct?

What is integrity?

What You Should Know About Keystone Human Services’ Code of Conduct (continued)

Who should follow the Code of Conduct?

What does this Code of Conduct have to do with me?

How do I use this Code of Conduct?

What You Should Know About Keystone Human Services’ Code of Conduct (continued)

Is everything I need to know in the Code of Conduct?

What about our subsidiaries outside of the United States?

Where do I fit into this?

What You Should Know About Keystone Human Services’ Code of Conduct (continued)

What about those who supervise others?

Where do I go for help?

What You Should Know About Keystone Human Services’ Code of Conduct (continued)

What happens when I use one of the Helplines?

Will I get into trouble for reporting?

What if I don’t want to leave my name?

Roles of Keystone’s Compliance and Integrity Program

Principle 1 Legal Compliance

Standard 1.1—Antitrust

Common Questions About Antitrust Laws

Standard 1.2—Tax

Standard 1.3—Fraud and Abuse

Common Questions About Fraud and Abuse Laws

Standard 1.4—Lobbying/Political Activity

Personal Political Activity

Organization Political Activity

Lobbying

Common Questions About Political Activity

Standard 1.5—Environmental

Common Question About Environmental Impact

Standard 1.6—Discrimination

Common Questions About Discrimination

Principle 2 Business Ethics

Standard 2.1—Honest Communication

Standard 2.2—Misappropriation of Proprietary Information

Common Questions About the Misappropriation of Proprietary Information

Standard 2.3—Employee/Vendor Screening

Principle 3 Confidentiality

Standard 3.1—Information Related to the People We Support

Common Questions About Information Related to the People We Support

Standard 3.2—Proprietary Information

Common Question About Proprietary Information

Standard 3.3—Personnel Actions/Decisions

Common Question About Personnel Actions/Decisions

Principle 4 Conflicts of Interest

Standard 4.1—Outside Financial Interests

Common Question About Outside Financial Interests

Standard 4.2—Services for Competitors/Vendors

Common Question About Services for Competitors/Vendors

Standard 4.3—Participation on Boards of Directors/Trustees

Common Question About Participation on Boards of Directors/Trustees

Standard 4.4—Honorarium

Common Question About Honorarium

Principle 5 Business Relationships

Standard 5.1—Gifts and Gratuities

Standard 5.1—Gifts and Gratuities (continued)

Usually OK

Standard 5.1—Gifts and Gratuities (continued)

Always Wrong

Standard 5.1—Gifts and Gratuities (continued)

Always Ask

Standard 5.1—Gifts and Gratuities (continued)

Other Considerations on Gifts and Gratuities:

Common Questions About Gifts and Gratuities

Standard 5.2—Contracting

Common Question About Contracting

Standard 5.3—International Bribery

Foreign Corrupt Practices Act

Activities Violating the FCPA include:

Steps to Avoid Prohibited Actions:

Standard 5.3—International Bribery (continued)

Facilitating or “Grease” Payments

Common Questions About International Bribery

Principle 6 Protection of Assets

Standard 6.1—Internal Control

What You Should Know About
Keystone Human Services’
Code of Conduct

What You Should Know About
Keystone Human Services’
Code of Conduct (continued)

What You Should Know About
Keystone Human Services’
Code of Conduct (continued)

What You Should Know About
Keystone Human Services’
Code of Conduct (continued)

What You Should Know About
Keystone Human Services’
Code of Conduct (continued)

Roles of Keystone’s
Compliance and Integrity Program

Principle 1
Legal Compliance

Principle 2
Business Ethics

Principle 3
Confidentiality

Standard 3.1—Information Related to the
People We Support

Principle 4
Conflicts of Interest

Principle 5
Business Relationships

Principle 6
Protection of Assets