HMMA Business Partner Code of Conduct – Business Ethics

 

HMMA Business Partners are expected to adhere to the highest standards of ethical conduct when dealing with their employees, suppliers, vendors, customers, contractors, business associates, governmental entities, and the public.

HMMA Business Partners are also expected to be familiar with and strictly follow HMMA’s Business Ethics Policy (HR-AL-HR-TR-S-00054) when interacting with HMMA Team Members.  Among other things, HMMA’s Business Ethics Policy prohibits HMMA Team Members from soliciting and/or accepting (and HMMA Business Partners from offering and/or providing):

  • Gifts given to HMMA Team Members on a single occasion that have a value in excess of $50.00, or gifts given to a Team Member on multiple occasions throughout the calendar year that have an aggregate value in excess of $100.00.
  • Entertainment (g., tickets to sporting events, plays, or charity events, golf outings, receptions, conference / convention expenses) provided to Team Members on a single occasion that have a value in excess of $100.00, or entertainment provided to Team Members on multiple occasions throughout the calendar year that has an aggregate value in excess of $200.00.  The entertainment provided must have a clear business purpose or objective, and there must be an expectation of reciprocity (i.e. HMMA Team Member paying for the next similar entertainment event) within a reasonable time period.
  • Meals provided to HMMA Team Members on a single occasion that have a value in excess of $75.00, or meals provided to a Team Member on multiple occasions throughout the calendar year that have an aggregate value in excess of $150.00. The meal provided must have a clear business purpose or objective, and there must be an expectation of reciprocity (e., HMMA Team Member paying for the next meal) within a reasonable time period.
  • Airfare, hotels, transportation, or lodging of any kind. However, Team Members are allowed to travel by automobile or taxi with a Business Partner if the travel is related to official HMMA business and if the travel costs associated with the shared automobile or taxi ride does not exceed $50.00.
  • Personal discounts for goods or services that are not offered generally to all HMMA Team Members (g., HMMA’s approved H-List).
  • Future benefits to HMMA Team Members or their relatives.
  • Any personal or financial benefit that may improperly influence an HMMA Team Member’s judgement in the conduct of official HMMA business.

HMMA Business Partners should immediately contact HMMA’s General Counsel if they have any questions about HMMA’s Business Ethics Policy or if they become aware of any HMMA Team Member violating or potentially violating HMMA’s Business Ethics Policy. Reports of potential violations of HMMA’s Business Ethics Policy may also be made anonymously by leaving a voicemail message on HMMA’s Compliance Hotline at 1-844-LGL-CPLY (1-844-545-2758), or by email at compliance@hmmausa.com.

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