Please direct any questions or comments you have regarding The MED Group’s Code of Conduct to Todd Walling, Director of Contract Administration, 800-825-5633, ext. 104, or twalling@medgroup.com.

A. General Ethics Policies

1. Mission Statement: "Partnering to Enhance Our Members' Success"

   When we speak of partnering, we think of a triple-win scenario. We strive to benefit our Member, any third party with whom we partner (suppliers, trade and professional associations, consumer groups), and our own corporation. We are not "just in it for us,” but hope to facilitate win-win-win propositions at every opportunity. The word enhance implies that our Members are already successful...and they are. We accept only a small percentage of applicants for MED membership, thus insuring that we keep the quality of MED standards at the highest possible level. Notice the emphasis on Members in the mission statement. They are the focus of our mission and we do our very best to never lose sight of that fact. And finally, the success we are speaking to is not just financial success, although that is obviously important. We want our Members to be completely successful...to have great corporate cultures with happy employees and highly satisfied customers...to have fun while they grow and change and improve...to enjoy life to its fullest as it was intended.

2. Foundation of Values:
   • To honor and uphold the authority of our leaders.
   • To concentrate and focus on our mission.
   • To speak positively and encourage others.
   • To devote time to recreation and reflection.
   • To revere those with wisdom.
   • To dignify the gift of life.
   • To support traditional family values.
   • To utilize only what is rightfully ours.
   • To value honesty and tell the truth.
   • To respect the property and rights of others.


3. Other Ethical Policies

   Other ethical policies include adherence to all applicable laws, business relationships with companies other than suppliers, outside employment by employees, the protection of confidential and proprietary information, the protection of company assets, respect for copyright, accurate accounting and financial reporting, fair competition toward competitors, policies against industrial espionage, sexual harassment, and a commitment to diversity programs in hiring and promotion.

1. NO GIFTS TO MED EMPLOYEES: No MED employee shall accept gifts, entertainment, favors, honoraria or personal services payments, other than of nominal value, from any participating supplier. Prohibitions apply to immediate family members (spouse and dependents) of employees as well as the employees themselves. In some cases, exceptions may be granted if spouses of employees are employed by participating suppliers and stock ownership is incidental to that employment. In these cases, disclosure and recusal by the employee from any decisions regarding that supplier may be adequate.
2. NO EQUITY OWNERSHIP BY MED EMPLOYEES: No MED employee shall own equity in any participating supplier. This provision excludes equities owned in mutual funds over which the individual exercises no investment control, and in completely blind trusts. New employees who come to MED with substantial deferred compensation in the form of equity in participating suppliers which cannot be liquidated without a substantial loss of value may retain that interest, but must disclose it to the company and recuse themselves from any decisions involving the participating supplier in which they hold the interest.
3. NO SUPPLIER EQUITY IN MED: No participating supplier shall be permitted to own equity in The MED Group.
4. NO GIFTS TO NON-MED EMPLOYEES WHO CAN INFLUENCE CONTRACTING: No non-employee director, officer or advisor of MED who is in a position to influence MED contracting decisions shall accept any gift, entertainment, favor, honoraria or personal services payment, except of nominal value, from any participating supplier. (For advisors on purchasing committees, this restriction may be limited to suppliers in the area which they advise.) This provision applies to advisors who serve or stand on committees providing advice to MED. Conflict of interests must be disclosed every time advice is communicated to decision-making committees or individuals.
5. NON-MED EMPLOYEES TO RECUSE THEMSELVES IF THEY HAVE RECEIVED GIFTS: Non-employees who are in a position to influence MED contracting decisions shall be required to recuse themselves from any negotiations or decisions relating to a supplier from whom they have received such items.
6. NON-MED EMPLOYEES TO RECUSE THEMSELEVES IF THEY HAVE EQUITY INTERESTS: Non-MED employees who are in a position to influence MED contracting decisions and have such equity ownership shall be required to recuse themselves from any negotiations or decisions relating to that supplier.
7. NO NON-MED EMPLOYEE ADVISORS WITH EXTENSIVE EQUITY INTERESTS: No non-MED employee director, officer or advisor who is in a position to influence MED contracting decisions shall serve as advisor in an area in which they hold extensive equity investments.
8. LIMITATION OF EQUITY INVESTMENT BY MED IN SUPPLIERS: MED will not hold a corporate equity interest in any participating supplier, unless the acquisition of the equity interest demonstrably benefits MED Group members by creating a source of a product or service where there is no other source, or very limited sources. Further, executive management team approval shall be required for any such investment.
9. DISCLOSURE OF EQUITY INVESTMENTS IN SUPPLIERS: Any MED equity interest in any participating or potential supplier shall be fully disclosed to MED members and publicly disclosed on the company website.
10. NO COMMITMENTS PERMITTED IF MED HAS EQUITY INVESTMENT: MED shall not impose an obligation, commitment or any other requirement that in any way obligates a member to purchase goods or services from such a participating supplier in which MED has an equity investment.
11. INSIDER TRADING: MED explicitly prohibits insider trading by employees based on any knowledge of suppliers or their prospects gained through their employment.
12. CONFLICT OF INTEREST INFORMATION ASSEMBLY: MED conducts regular and periodic checks to collect information covered by the conflict of interest section in the Code of Conduct, in its members, employees, officers, and members of any advisory boards. The MED Group compliance officer will be in charge of collecting all conflict of interest information.

1. CONTRACTING PHILOSOPHY: At the foundation of The MED Group’s contracting process is Member input and involvement. This process requires MED staff seek discipline-specific member input into contract decisions. MED staff determines the vehicle best suited to gain Member involvement. In some instances, it may be through standing MED Group networks; while in other instances it may be through product-specific task forces. The core of The MED Group’s contracting philosophy is to utilize a contract proposal process that has high integrity and involves Members to the greatest practical degree. Contract advisory teams, composed of various member representatives, respond to this approach with high levels of commitment and support. All supplier proposals will be evaluated based on qualitative (non-financial) factors combined with “financial factors.” Members have provided extensive input regarding the criteria to be used in the evaluation of the proposals submitted.
2. RIGHT TO COMMUNICATE DIRECTLY WITH SUPPLIERS: MED permits Members to communicate directly with all suppliers and assess products or services provided by all suppliers.
3. RIGHT TO PURCHASE CLINICAL PREFERENCE ITEMS OFF CONTRACT: MED permits Members to purchase clinical preference items directly from suppliers who do not contract with MED.
4. NOTICE OF PENDING CONTRACTING PROCESSES: MED informs potential suppliers of the process for seeking and obtaining contracts and provides interested suppliers the opportunity to solicit contracts. Upcoming contracting processes are listed on the company’s public website. (Updates which do not extend existing contracts need not be pre-noticed.)
5. FAIR TECHNOLOGY EVALUATION PROCESS: MED conducts technology assessments in the development of member product councils. These councils meet in a fair, timely, confidential and unbiased manner, with an opportunity for review of decisions by suppliers whose product or services are evaluated. MED provides the opportunity for all members to have input to the technology assessment process by direct communication with the MED Group Purchasing department and product councils.
6. SUPPLIER GRIEVANCE PROCEDURES: Any supplier grievance related to access for innovative clinical products or services can contact either The MED Group CEO or Senior Vice President of Group Purchasing. The supplier grievance procedure is actively disclosed to all participating and prospective suppliers during initial communication between MED and the supplier.
7. NO ADMINISTRATIVE FEES IN THE FORM OF SUPPLIER EQUITY: MED does not permit administrative fees to be paid in the form of supplier equity.

1. DISCLOSURE OF CONTRACTS TO MEMBERS: MED enables its Members to have access to product and pricing data, along with other related contract information, on existing contracts.
2. DISCLOSURE OF SUPPLIER VOLUME: MED enables full disclosure to each Member of all supplier volume collected on the individual member’s behalf.

1. DESIGNATED COMPLIANCE OFFICER: MED has a designated compliance officer to oversee compliance with the HIGPA code and other ethics commitments, to do annual reporting, and to raise other policy issues of ethical significance with the executive management team.
2. REVIEW BY EXECUTIVE MANAGEMENT TEAM: The executive management team of The MED Group meets at least annually to hear from the compliance officer and to discuss any issues brought forward.
3. ANNUAL REPORT ON CODE OF CONDUCT PERFORMANCE: An annual report is made available to the MED executive management team and Members regarding compliance with the ethical policies. A summary report is made available to the public.