The Code of Conduct must govern the actions of CAF. It is to be read by employees and service providers who need to become familiar with the job specific legal requirements and recognize circumstances that may raise issues. They are required to sign the Acknowledgement Form confirming that they have received and read the Code of Conduct and are prepared to adhere to its terms.
2. Business Ethics
3. Legal and Regulatory Compliance
4. Professional Conduct
5. Conflicts of Interest
6. Appropriate use of resources
CAF is committed to the highest standard of business ethics and integrity, and requires honesty when representing CAF. CAF is committed to ensuring that its billing and reimbursement practices comply with applicable laws, regulations, guidelines and policies of the countries in which CAF operates and that all billing is accurate.
CAF payment and other transactions are to be properly authorized by management, and are to be accurately and completely recorded in accordance with generally accepted accounting principles and established corporate policies. This serves as basis for managing the business and is important to meeting obligation to the orphans and vulnerable children, the widows and their children, the elderly, the mentally disabled, the physically disabled including the deaf and the blind, students, patients and the public at large, and suppliers and others. CAF’s high standard of accuracy and documentation is necessary for tax financial reporting requirements.
The duty to report accurate and truthful information also applies to our internal dealings. All work-time and expenses recorded are to be reported accurately and honestly.
CAF prohibits its employees and other services providers from offering, paying, asking for, or accepting any money or other benefit-including and not limited to- patient referrals, purchases, leases or orders. All contracts and other referral sources are to follow all applicable laws.
CAF engages in activities that are subject to the countries in which CAF operates and its antitrust laws. Generally, those laws prohibit competitors from entering into agreements to fix prices or to reduce price competition.
CAF employees should not provide information about CAF to business competitors. In addition, employees are to refrain from engaging in unfair practices that might restrict competition.
Billing is to comply with all applicable laws, rules and policies. Employees who handle patient charges, claims and records are to accurately document and report services and supplies. CAF prohibits its employees or agents from knowingly presenting, or causing to be presented, claims for payment or approval, which are false, fictitious or fraudulent.
CAF policies and various laws of the countries in which CAF operates prohibit fraudulent claim activities. The laws of the countries in which CAF operates prohibit conduct such as knowingly submitting a false or fraudulent claim, or using or making false statement to get false or fraudulent claim paid. Other laws governing NGOs integrity also look for ways to reduce fraud and abuse. CAF and its employees and other service providers can be prosecuted for filling inaccurate claims for reimbursement and can be subject to civil fines, criminal penalties or both.
CAF expects employees to report known or suspected activity of this type to the Corporate Compliance Office or the Management Committee. Employees who lawfully report false claims or other fraudulent conduct or who otherwise assist in an investigation, action or testimonies are protected from retaliation to the furthest extent possible under the laws of the countries in which CAF operates.
Performing routine audits or reviews and monitoring, along with internal controls, help CAF prevent and detect fraud, waste and abuse.
Travel and entertainment expenses of an employee must be consistent with his/her job responsibility and the needs and resources of CAF. Employees are encouraged to participate in and attend educational workshops, seminars and training sessions.