H & H Medical L.L.C (dba. Home and Healthy) adheres to the principles of truth in advertising, and all information accurately represents the organization’s scope of services provided, licenses, price claims or testimonials.

Our Ethics Compliance and Fraud Policies

Home and Healthy adheres to the principles of truth in advertising, and all information accurately represents the organization’s scope of services provided, licenses, price claims or testimonials.

Ethics

All directors, managers, and employees shall behave honestly and ethically at all times and with all people. They shall act in good faith, with due care, and shall engage only in fair and open competition, by treating ethically competitors, suppliers, customers, and colleagues. They shall not misrepresent facts or engage in illegal, unethical, or anti-competitive practices for personal or professional gain. No director, manager or employee may offer or accept bribes, kickbacks or substantial gifts either directly or through another party.
This fundamental standard of honest and ethical conduct extends to the handling of conflicts of interest. All directors, managers, and employees shall avoid any actual, potential, or apparent conflicts of interest with the Company and any personal activities, investments or associations that might give rise to such conflicts. They shall not use the Company for personal gain, self-deal, compete with the Company or take advantage of corporate opportunities other than on behalf of the Company. They shall act on behalf of the Company free from improper influence or the appearance of improper influence on their judgment or performance of duties. There is a likely conflict of interest if, for example, a director, manager or employee causes the Company to engage in business transactions with relatives or friends; receives loans or guarantees of obligations from the Company (or a third party because of his or her relationship to the Company); has more than a modest financial interest in the Company’s competitors, suppliers, or customers; or uses non-public information for personal gain or for gain by relatives or friends.
If a director, manager or employee involved in a particular decision has a relationship—business, financial, or otherwise—with a competitor, supplier, customer, candidate for employment or other people, that might impair or appear to impair his or her independence in making that decision, he or she shall disclose such relationship to the Chairman of the Audit Committee. No action may be taken with respect to the transaction or party giving rise to the actual, potential or apparent conflict unless and until such action has been approved by the Audit Committee.

Compliance

In conducting the business of the Company, all directors, managers, and employees shall comply with applicable governmental laws, rules, and regulations at all levels of government in the United States and in any non-U.S. jurisdiction in which the Company does business. If a director, managers or employee is unsure whether a particular action would violate applicable law, rule, or regulation, he or she should seek the advice of the Company’s outside counsel before undertaking it. It is always illegal to trade in the Company’s securities while in possession of material, non-public information, and it is also illegal to communicate or “tip” such information to others. No written or electronic documentation is to alter or destroyed in anticipation of a request or as a result of the request of that documentation by an authorized lawful investigation.
The Company’s directors, managers, and employees shall take all reasonable steps to protect the confidentiality of non-public information about the Company and its customers and to prevent the unauthorized disclosure of such information unless required by applicable law or regulation or legal or regulatory process.

Policy Against Fraud

 While there is no one official definition of fraud; the Theft Acts of 1968 and 1978 list a multitude of offenses that are considered to be a fraud. The term fraud is used to describe acts such as deception, bribery, forgery, extortion, corruption, theft, conspiracy, embezzlement, misappropriation, false representation, concealment of material facts and collusion.
In regards to this policy, fraud may be defined as the use of deception with the intention of obtaining an advantage, avoiding an obligation or causing loss to another party.
This policy is concerned with fraud committed by H & H Medical personnel or contractors in the course of their work. Guidance on issues arising from the private and personal activities of staff which may impinge on the performance of their duties or risk bringing discredit to H & H Medical.

Occupational Fraud and Abuses Fall Into Four Main Categories:

  • Theft, the misappropriation or misuse of assets for personal benefit;
  • Bribery and corruption;
  • False accounting and/or making fraudulent statements with a view to personal gain or gain for another: for example falsely claiming overtime, travel, and subsistence, sick leave or special leave (with or without pay)
  • Externally perpetrated fraud against an organization.

H & H Medical Policies & Principles:

H & H Medical is committed to preventing fraud and corruption from occurring by creating an anti-fraud culture. H & H Medical will comply with the requirements of Government Accounting to:
  • Develop and maintain effective controls to prevent fraud;
  • Ensure that if fraud occurs a vigorous and prompt investigation takes place;
  • Take appropriate disciplinary and legal action in all cases, where justified;
  • Review systems and procedures to prevent similar frauds;
  • Investigate whether there has been a failure in supervision and take appropriate
  • disciplinary action where supervisory failures occurred; and
  • Record and report all discovered cases of fraud.

The Following Policies and Principles Apply at H & H Medical:

  • All staff must have, and be seen to have, the highest standards of honesty, propriety and integrity in the exercise of their duties.
  • H & H Medical will not tolerate fraud, impropriety or dishonesty and will investigate all instances of suspected fraud, impropriety, or dishonest conduct by staff or external organizations (contractor or client).
  • All staff must not defraud H & H Medical, other H & H Medical staff, H & H Medical patients in any way.

Right to Action 

H & H Medical will take action – including dismissal and/or criminal prosecution – against any member of staff defrauding (or attempting to defraud) H & H Medical, other H & H Medical staff, or H & H Medical patients.
  • H & H Medical will take action – including criminal prosecution – against external organizations defrauding (or attempting to defraud) the H & H Medical, H & H Medical staff in the course of their work or H & H Medical patients.
  • H & H Medical will co-operate fully with an external investigating body.
  • H & H Medical will always seek to recover funds lost through fraud.
  • All frauds will be reported to an Internal Audit.

In the Event of Discovery or Suspicion of Fraud

H & H Medical has established arrangements for staff to report any concerns they may have without fear of prejudice or harassment. This applies to concerns relating to fraud and to any other concerns within the context of the Public Interest Disclosure Act 1998.

Concerns which should be reported include, but are not limited to, staff committing or attempting to commit:

  • Any dishonest or fraudulent act;
  • Forgery or alteration of documents or accounts;
  • Misappropriation of funds, supplies or other assets;
  • Impropriety in the handling or reporting of money or financial transactions;
  • Profiting from an official position;
  • Disclosure of official activities or information for advantage;
  • Accepting or seeking value from third parties by virtue of official position or duties; and
  • Theft or misuse of property, facilities or services.

External organizations’ actions which should be reported include:

  • Being offered a bribe or inducement by a supplier;
  • Receiving fraudulent (rather than erroneous) invoices from a supplier;
  • Reported allegations of corruption or deception by a supplier.

H & H Medical has established and maintains a Fraud Response Plan, which sets out guidance to senior staff in the event of fraud being discovered or suspected.

Under the Plan:

  • Incidents will be logged in a Fraud Register, which contains details of allegations, investigations, and conclusions;
  • Frauds and allegations of fraud will be investigated by an appointed suitably qualified senior member of staff independent of the area under suspicion;
  • Progress on investigations will be reported to the H & H Medical Board of Directors as a standing item on the agenda.

Anti-Fraud Culture

H & H Medical seeks to establish and create an anti-fraud culture. The creation of an anti-fraud culture underpins all work to counter fraud. All H & H Medical staff should understand the risk of fraud faced by the office, that fraud is serious and diverts resources away from the H & H Medical’s primary objectives.

Treasurer / Secretary & Board Member for Finance

The treasurer, secretary and Board Member for Finance are responsible for establishing the internal control system designed to counter the risks faced by H & H Medical. Together they are accountable for the adequacy and effectiveness of these arrangements. Managing fraud risk should be seen in the context of the management of this wider range of risks.

The Board Member for Finance 

The Board Member for Finance is responsible for making arrangements for investigating allegations of fraud. These arrangements include the appointment of a suitably qualified senior member of staff to lead the investigation. The Board Member for Finance will be responsible for receiving the report of the Independent Compliance Officer and considering an appropriate response.

The Director of Human Resources

The Director of Human Resources will be responsible for enforcing H & H Medical anti-fraud policies, including:

  • Instigating disciplinary and legal action (both civil and criminal) against the perpetrators of fraud;
  • Taking disciplinary action against supervisors where supervisory failures have contributed to the commission of fraud;
  • Providing confidential advice to staff who suspect a member of staff of fraud.

Appointed Investigator

The appointed senior member of staff will be responsible for investigating allegations of fraud including:

  • Carrying out a thorough investigation if fraud is suspected, with the support of Internal Audit, where necessary gathering evidence, taking statements and writing reports on suspected frauds;
  • Liaising with the Treasurer and the Board Member for Finance where investigations conclude that a fraud has taken place;
  • Identifying any weaknesses which contributed to the fraud; and if necessary, making recommendations for remedial action.

To carry out these duties the appointed member of staff will have unrestricted access to H & H Medical, the Board Member for Finance, Human Resources Director, the Director of Finance, and H & H Medical’s legal advisers.

Management and Supervisors

Managers and supervisors are the first line of defense against fraud. They should be alert to the possibility that unusual events may be symptoms of fraud or attempted fraud and that fraud may be highlighted as a result of management checks or be brought to attention by a third party. They are responsible for:

  • Being aware of the potential for fraud;
  • Ensuring that an adequate system of internal control exists within their area of responsibility, appropriate to the risk involved and those controls are properly operated and complied with;
  • Reviewing and testing control systems to satisfy themselves the systems continue to operate effectively.

Managers should inform their supervisor if there are indications that an external organization (such as a contractor or patient) may be trying to defraud (or has defrauded) H & H Medical or its staff carrying out their duties.

They should also inform their supervisor if they suspect their staff may be involved in fraudulent activity, impropriety or dishonest conduct.

Supervisors should contact the Board Member for Finance immediately on being alerted to such suspicions. Time is of the essence of reporting suspicions. Managers should, therefore, inform the Board Member for Finance direct if their supervisor is absent. In turn, they will ensure that H & H Medical is kept informed of developments.

Managers and supervisors should take care to avoid doing anything which might prejudice the case against the suspected fraudster. Separate advice on dealing with fraud is contained in a fraud response plan circulated to designated staff involved in reporting or investigating individual allegations of fraud.

H & H Medical Staff

All staff must have, and be seen to have, the highest standards of honesty, propriety, and integrity in the exercise of their duties. H & H Medical staff are responsible for:

  • Acting with propriety in the use of official resources and in the handling and use of public funds whether they are involved with cash or payment systems, receipts or dealing with contractors or suppliers;
  • Reporting details of any suspected fraud, impropriety or other dishonest activity immediately to their manager or immediate supervisor. assisting in the investigation of any suspected fraud.

Staff reporting or investigating suspected fraud should take care to avoid doing anything which might prejudice the case against the suspected fraudster.