1. Written Standards of Conduct, Policies and Procedures.

The Code of Ethics and Employee Handbook sets clear expectations about how we should act toward the individuals and families we support, the vendors with whom we do business, the government entities that regulate and fund us, and even how we interact with our colleagues.

We also have specific policies and procedures addressing:

• Conflict of Interest
• Compliance, Ethical Responsibility Reporting
• False Claims and Whistleblower
• Incident Reporting
• Employee Time and Attendance
• Documentation of Services Rendered
• Billing for Services including processes to detect, record and correct errors
• Gift Acceptance
• Consultant and Vendor Agreements
• Abuse and Neglect

2. The Compliance Officer and Compliance Committee

The agency’s Compliance Officer coordinates and monitors compliance activities across the agency, with the help of a committee made up of employees from across the agency. The Compliance Committee meets to monitor compliance activities, evaluate the effectiveness of the Compliance Program, discuss best practices and recommend changes when appropriate.

3. Education and Training

All staff receive Compliance training when they are first hired and every year after that. Members of the Board of Directors also attend annual training.

4. Internal Lines of Communication

ADAPT is committed to fostering open communications at all levels within the organization. If you are an employee, vendor or contractor who thinks there may be an issue with abuse, fraud or waste, you are urged to report the situation to a member of ADAPT’s Management Staff, or to:

• Michael Matrone, Chief Compliance Officer, (212) 683-6700, ext. 1137, mmatrone@adaptcommunitynetwork.org
• ADAPT’S Ethics Hotline – (212) 683-6700, ext. 1132
• Tricia Singh, Chief People Officer, (212) 683-6700, ext. 1257, tsingh@adaptcommunitynetwork.org

For an employee, reporting misconduct is an obligation set out in our Code of Ethics, whenever you have reason to believe it is taking place. No attempt will be made to identify an individual who requests anonymity, and even if you choose to use your name, your name will not be revealed unless required by law or usual circumstances.

No person who makes a report in good faith has to worry about retaliation. The agency is committed to responding promptly and appropriately.

5. Disciplinary Guidelines

Every employee is expected to uphold the agency’s high ethical standards and any violation of the Code of Ethics is subject to a disciplinary action, which could result in sanctions, from warnings to suspension or termination.

6. Monitoring and Auditing

The agency works hard to prioritize risk and monitor accordingly taking into account changes in regulatory requirements, operations or business practices.

7. Responding to Compliance Issues

As part of its Compliance Program, ADAPT will insure that all reports of suspected waste, fraud or abuse or violations of the agency Code of Ethics will be immediately and objectively investigated and resolved promptly.

8. Protection from Retaliation

To ensure that no one who makes a good faith report of a problem is punished in any way at all, the Agency is committed to disciplining any employee who discharges, suspends, threatens, or otherwise discriminates against an employee who in good faith initiates or assists in reporting a suspected violation of our Code of Ethics.