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Table of Contents
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Introduction from the President and CEO back to top
The Dental Care Plus Holding Company and its subsidiaries, known collectively as The Dental Care Plus Group (DCPG), owes its success to delivering on its promises and building a reputation that has become its most valuable asset. The Dental Care Plus Group thrives through internalizing a simple but timeless business truth: high performance standards are only sustainable when backed by commitment to integrity, fairness and good judgment.
DCPG’s vision for ongoing growth requires a collective ethical compass honored by every DCPG employee and member of the board of directors. A written Code of Conduct ensures that all employees understand their role in upholding the company’s reputation. Public dissemination of the Code of Conduct ensures that all stakeholders – shareholders, dentists, members and employers – understand the standards to which they should hold every employee and board member.
All DCPG employees and board members are expected to review the Code of Conduct and to refer to its guidelines as necessary. However, the Code of Conduct is not intended to be an exhaustive resource on company policy. It is intended to articulate the core ideas that drive our behavior and decisions.
As a “living document,” the Code of Conduct will never be finalized. A formal review will be conducted by the end of the second quarter each fiscal year, and additional changes will be considered whenever necessary to ensure its ongoing relevancy. Employees with suggestions for enhancing or clarifying any aspect of the Code of Conduct should submit their comments in writing to the President/CEO and copy their direct supervisor and/or department head.
I want to extend my thanks to all of the senior managers and members of the board of directors who participated in developing the DCPG Code of Conduct.
Anthony A. Cook, M.B.A., M.S.
President and CEO
A Mission with Momentum back to top
In 1986, 20 leading dentists practicing in the greater Cincinnati and Northern Kentucky community decided to test the adage: the best defense is a strong offense.
While their colleagues in other markets resisted the trend toward managed care or capitulated without consideration of the consequences of practicing dentistry through a poorly conceived HMO, DCPG’s founding shareholder dentists chose to exert influence on managed care in their market by creating a plan that works – for dentists, for members, for employers and for shareholders.
The Dental Care Plus Group’s mission -- then and now -- is to be a competitive, professional and qualified network of people providing competitive, quality dental managed care services in the most cost-effective and responsive manner. DCPG strives to maintain the benefits of the Independent Practice Association (IPA) concept, including quality care, fee-for-service, and autonomy in dental practices.
The mission is realized day-to-day through a business philosophy that balances the interests of all key stakeholders: shareholders, dentists, members and employers. All stakeholders require and deserve our commitment and consideration of their interests. We pride ourselves on providing the best possible service to our members and business partners, and understanding that without their support and trust, our business would cease to exist.
Ethical Conduct: Living Up To Expectations back to top
The DCPG brand is built upon persistent adherence to dependability, honesty and thorough knowledge of the industry and markets in which we conduct business. We strive every day to be a company with whom other businesses want to work, to be the company against which our competitors are benchmarked, to be a company open to feedback and a partner that is responsive to our stakeholders’ needs in a dynamic economy. We are upfront about our capabilities, deliver upon our promises and are courteous in all our interactions. The brand is sustained every day by the action and decisions of every employee.
All DCPG employees are held to the same high standard of conduct and performance. The mere appearance of impropriety can be damaging to our reputation and image. Core areas of conduct include but are not exclusive to:
- Dealing consistently and honestly with all clients, members and providers.
- Handling requests of clients, members and providers promptly and cheerfully.
- Exercising tact, patience and courtesy at all times.
- Taking personal interest and initiative in solving problems.
- Protecting the rights and confidentially of clients, members and providers, and assuring that health information protected under the provisions of HIPAA* is never violated.
*See explanation of HIPAA under the Privacy and Securities Policies section of the Code of Conduct.
Marketing, advertising and formal communications about DCPG, its products and its capabilities are never misleading. DCPG believes that great thinking, quality products and commitment to service provide ample competitive advantage. We do not claim what we have not earned nor do we promise what we cannot deliver.
Ethical Decision-Making
Most employees face ethical questions in the course of their work, and most situations offer several possible courses of actions. Making the right decision should always include careful consideration of what is right.
DCPG employees are asked to apply the “Front Page” test in these situations. In other words, if your decision appeared as a front-page story in your local newspaper – a newspaper sure to be read by your family, colleagues, friends and neighbors – would you proceed with the decision or choose another course?
Another question to consider when facing a unique ethical dilemma unlikely to be noticed or repeated: “What if I did this 100 times rather than once?” If the exposure or the consequences of a potential course of action increases with repetition, then DCPG employees should search for an alternative.
Reporting Unethical Activity
Employees with questions or concerns about unethical conduct, or who feel they have knowledge of a potential violation of DCPG’s Code of Conduct must report the incident in question. Employees have several options for seeking clarification on the Code of Conduct’s application and for reporting violations. Based upon the nature of the incident and the anticipated consequences of reporting it, the employee should choose the option with which he or she is most comfortable.
- Employees may choose to speak with their immediate supervisor or department head.
- If employees are uncomfortable speaking with an immediate supervisor or department head, or feel that the issue was not sufficiently resolved through this channel, they may speak to company officers, including the CEO and CFO.
- Employees who feel that their questions or concerns are inadequately addressed by senior management, or who wish to report their issue anonymously, may submit their questions or concerns in writing to one of the following board members:
chairman of the audit committee
or
chairman of the DCPG board of directors.
Mailing addresses can be found on the DCPG Web site (www.dentalcareplus.com) in the “corporate” tab under “board of directors”.
All submissions will be kept confidential. Employees will not face retaliation for choosing this remedy to resolve issues with ethical implications.
DCPG employees are subject to disciplinary action for violating DCPG’s Code of Conduct, SEC or state regulatory requirements, or HIPAA policies and procedures. Violations can result in disciplinary action up to and including discharge.
Professional Relationships with Business Partners and Vendors back to top
Employees of DCPG must not solicit nor accept for personal benefit directly or indirectly any gift, loan or any item of substantial monetary value from a person, vendor or company with whom DCPG does business or who is seeking to do business with DCPG. Employees should always check with their department head before giving or receiving any gifts or favors from persons outside the company.
Employees responsible for working with vendors for services and goods necessary to the stability and growth of DCPG business should apply the same Code of Conduct in these dealings as the company upholds when dealing with members, dentists, shareholders and employers. All transactions should be outlined in writing. All interaction should be professional, honest, transparent and ethical. All reimbursement should be prompt.
DCPG strives for long-term mutually-beneficial relationships with competent, trustworthy and service-oriented vendors. Accomplishing this objective requires DCPG to behave honorably and professionally toward vendors as well as demanding similar consideration from vendors.
Work Environment back to top
DCPG’s reputation for exceptional customer service relates directly to the respect that DCPG fosters among its employees. Harmonious, productive working relationships foster strong, consistent performance and employee loyalty as well as respect for DCPG stakeholders.
DCPG’s policies that affect the employee’s work environment reflect high ethical standards and are in compliance with Federal and State laws, where applicable. Employees should refer to the DCPG Employee Handbook for comprehensive explanations of the following policies:
- Equal Employment Opportunity policy;
- Anti-Harassment policy;
- Open Door policy;
- Privacy and Security Policies and Procedures;
- Conduct
- Excessive absences or tardiness;
- Misuse of DCPG time;
- Leaving work without permission;
- Insubordination;
- Use, possession, sale or being under the influence of alcohol, illegal drugs or other intoxicants or controlled substances;
- Any form of harassment, including sexual harassment;
- Theft or any other crime on DCPG premises or during working hours;
- Falsification of documents or company records;
- Misuse or unauthorized removal or disclosure of confidential information or records;
- Absence without notification;
- Damaging or using DCPG-owned equipment of facilities without authorization;
- Fighting or creating conflicts with/or physically assaulting/attacking another employee or visitor while working;
- Dishonesty;
- Using abusive or threatening language toward a supervisor, another employee, client, provider or vendor;
- Threatening another employee with bodily harm;
- Unauthorized long distance phone calls charged to DCPG;
- Possession of a firearm or other weapon on DCPG property, including parking lots, or while engaged in DCPG business;
- Violations of DCPG’s Use of Technology Policy;
- Failure to follow dress or personal hygiene standards;
- Sleeping during working hours;
- Commission of a crime and/or engaging in outside conduct that DCPG deems incompatible with continued employment;
- Unauthorized overtime work.
Succeeding At DCPG
All employees should expect and receive clear communication about performance expectations and how performance will be evaluated. Performance-related rewards should also be clearly articulated and recorded in writing.
DCPG strives to provide clear policies regarding paid time off and leaves of absences necessary to maintain a healthy balance between work and other life obligations. The company has designed employee policies to provide employees with the flexibility to attend to family obligations, enjoy time away from work to recharge, and pursue career advancement of benefit to the employee and to DCPG.
DCPG is open to employee feedback regarding ways to further improve upon the company’s work environment and benefits to promote the long-term retention of quality employees. In addition, DCPG has a long history of benefiting from efficiencies and quality improvement measures initiated by staff working in every department at all levels of the company.
DCPG strives to be an “employer of choice” within its industry and to attract quality employees qualified to contribute their talent and expertise toward DCPG growth and profitability. Maintaining a quality work environment is, long-term, the company’s best recruitment strategy.
Use of Company Resources
Maintaining high performance from employees is contingent upon providing appropriate equipment, software and other resources necessary to conduct business efficiently and effectively. Employees are expected to seek approval from appropriate department heads or officers before purchasing these resources. In addition, employees are expected to master the utilization and application of available resources necessary for optimum job performance.
Because all capital investment and business expenses require allocation of DCPG resources which are generated to the benefit of DCPG shareholders, employees are reminded to use these resources judiciously. The employee handbook provides more comprehensive guidelines to the appropriate allocation and utilization of software, personal computers, printers, copiers, fax machines, company telephones, cellular devices, Internet access, office supplies and other resources.
Competitive information and databases of various stakeholders and business prospects are among DCPG’s most valuable resources. Careless handling of proprietary information of this kind through the loss of a laptop computer or hard copy versions as well as the unintentional emailing of this information to an unauthorized vendor could have serious repercussions for the company.
Privacy & Security Policies back to top
HIPAA
To comply with regulations of the Health Insurance Portability & Accounting Act of 1996 (HIPAA), all employees are trained on provisions of this Act as it pertains to his or her particular job responsibilities. This training usually occurs as part of a new employee’s orientation with DCPG, and it occurs within a reasonable time period after joining the company. Employees receive additional training as changes in HIPAA policies and procedures affect individual job responsibilities. Documentation of training is filed in the employee’s personnel file.
DCPG employees are subject to disciplinary action for violating HIPAA policies and procedures. Violations that jeopardize the privacy or security of protected health information (PHI) are particularly serious and can result in disciplinary action up to and including discharge.
Acquiring and Using Sensitive Information
Employees must maintain the privacy of non-public information on any company provided to DCPG in the course of business.
DCPG does not encourage nor condone improper methods to obtain competitive proprietary information, including inducing or attempting to induce another company’s present or former employees or third parties to disclose sensitive or proprietary information.
Employees of DCPG must not divulge non-public proprietary or sensitive information about DCPG during or after their tenure with the company. This provision extends to ideas, information and data. Disclosure of copyrighted material, trade secrets, customer lists, marketing plans, manuals, rating schedules, reimbursement schedules and other materials developed for business use is strictly prohibited and could result in legal action.
DCPG conducts background searches on all prospective employees. Federal law and/or state insurance regulations prohibit individuals convicted of a felony involving breach of trust or dishonesty from holding an insurance license.
Financial Disclosure and Management back to top
DCPG regularly submits reports on its financial performance, product designs and other company operations to various regulatory agencies, including (but not limited to) the U.S. Securities and Exchange Commission and the Ohio Department of Insurance. Management is responsible for the timeliness and accuracy of these filings; as well as full, fair and understandable disclosures accompanying these filings, as required by the applicable regulatory body.
All filings with the SEC and the ODI are public record. Copies may be obtained through these agencies or through a written request to the DCPG Chief Financial Officer. Several filings are also available in PDF form or through an Internet hyperlink on the company’s Web site under “company administration”.
DCPG shareholders receive regular updates on the company’s progress toward performance goals, business decisions and rationale, product designs and implications, and operational issues. In addition, shareholders receive an annual report and audited financial statement approximately 30 days prior to the annual shareholders meeting.
DCPG shareholders have full access to members of the board of directors and the company CEO/President whenever they have questions or feedback for the company. Forums are held throughout the year for shareholders to attend meetings with DCPG management. In addition, owners of Common A Shares have the opportunity to serve on various subcommittees and task groups charged with investigating various business policies and decisions, and advising the board of directors.
Media Relations Policy back to top
DCPG employees should be acquainted with and comply with the company’s approved Media Protocol. Only approved spokespersons are permitted to provide information or comment to any media outlet regarding DCPG policies, procedures or performance. The Media Protocol is in place to ensure that information released through these public vehicles is accurate, verified and professionally handled. The Protocol also alleviates employees without adequate information or who are uncomfortable with media inquiries from the pressure of offering responses.
Please direct all media inquiries to the Director of Corporate Communications. In the absence of the Director of Corporate Communications, all inquiries and statements will be managed by the DCPG CEO/President.
Conflicts of Interest back to top
DCPG board members and employees are expected to act in the best interests of DCPG and its shareholders throughout their tenure. Knowledge gained about DCPG, its partners or its competitors is not to be used for personal benefit or for harm against DCPG, whether intended or otherwise.
DCPG personnel decisions and selection of vendors for goods and services must never be compromised by personal interests. Any outside business interest that weakens or divides an employee’s interests from the interests of DCPG is a conflict. Any outside business interests which distracts the employee or board member from fulfilling his or her job requirements is a conflict.
Any potential conflicts of interest are to be reported immediately to the human resources representative, the employee’s immediate supervisor or the DCPG President/CEO.
It is impossible to provide an exhaustive list of potential conflicts, so employees are advised to consult with their immediate supervisor, the human resources department or the DCPG President/CEO if they believe that their actions within or outside of employment could be a conflict of interest. The following list provides several examples of situations that may present a conflict of interest:
- Ownership or significant financial interest by an employee or member of an employee’s immediate family in a business enterprise doing business with or seeking to do business with or competing with DCPG. In addition, business interests which adversely impact the employee’s job performance or which involve the use of DCPG’s equipment, supplies, facilities or name are prohibited.
- Serving as a director, officer, partner, consultant or in any other key role in any outside enterprise doing business or seeking to do business with DCPG.
- Approving insurance applications, handling underwriting transactions or handling claims for yourself, for members of your family.
- Maintaining outside employment that interferes with scheduled work for DCPG, impairs the employee’s effectiveness, results in publicity adverse to DCPG or could be construed as a conflict with DCPG interests.
- Any arrangement or circumstance, including family or other personal relationships, which might prevent the employee from acting in the best interests of DCPG.
- A business opportunity derived from DCPG or based upon confidential information not available to the public that could result in personal gain or cause adversity to DCPG interests.
Political Activities and Contributions back to top
DCPG does not directly endorse or contribute funds toward political candidates or issues. DCPG does belong to industry associations which monitor legislative, judicial and executive action on the state and federal level. These associations engage in lobbying activities that address the general interests of the insurance industry or dental insurance.
DCPG encourages employees to follow current events, vote and exercise the rights of their citizenship. However, employees are discouraged from advocating their political views during business hours or in company-sponsored forums. Polite discussion is permitted and often unavoidable in business environments, but heated exchanges or insulting remarks that damage working relationships and disrupt work is unacceptable. In addition, political activity during business hours, including soliciting donations, gathering signatures for petitions or disseminating political promotional materials such as flyers, bumper stickers, etc. is strictly prohibited.
Social Responsibility and Civic Activities back to top
Successful businesses have an obligation to support the communities which have fostered their success. For this reason, DCPG regularly sponsors and supports nonprofit activities which benefit local schools, youth activities and other worthwhile community service. In addition, DCPG supports nonprofit efforts related to advancement of medical/dental research and health awareness.
Criteria for determining support and the form that support will take are used to evaluate all requests for support. All sponsorship and underwriting requests should be forwarded to the Director of Corporate Communications who will evaluate the proposals and respond within 30 days.
DCPG employees are encouraged to participate in nonprofit activities as time allows. Permission to pursue these activities during business hours must be submitted to the employees’ direct supervisor and/or department head in advance for approval.
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