Delta Dental Ethics Guide
User Manual:
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Page Count: 85
- Table of Contents
- ethics
- Coporate Social Responsibility
- Outside Employment
- Workplace Safety
- Comminication with external parties
- Phyical Assets
- Intellectual Property
- Internal Accounting Controls
- General Compliance
- 3rd Parties
- Antitrust
- Giving Gifts
- Accepting Gifts
- Anti Corruption
- Conflict of Interest
- Reporting Options
- Our Values
- Disciplinary Action
3
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CONTENTS
4
Our Values
5
Ethics
Introduction
10
Raising Concerns
Reporting
Disciplinary Action
Management Responsibilities
Non-Retaliation/
Whistleblower Protection
Waiver Provision
17
Conflict of Interest
24
Anti-Corruption
27
Accepting Gifts
30
Giving Gifts
33
Antitrust and Fair
Competition
36
Selection and Use of Third
Parties/Procurement
39
Compliance with Laws and
Regulations
42
Accurate Books and
Records
45
Intellectual Property/
Confidential Information
Data Privacy
Records Management
52
Physical Assets
Computer Use
57
Communicating with
External Parties
Social Media
Trust in Advertising/
Reporting
Political Activist/Lobbying
63
Outside Employment
66
Workplace Safety, Health
and Diversity
Violence
Substance Abuse
Harassment
Armative Action/
Nondiscrimination
Labor Practice
76
Corporate Social
Responsibility
4
OUR VALUES
This Ethics Guide was crafted with these values in mind and is central to our
everyday behaviors. Our values should be embedded in everything we do
and inform the way we work.
Service Innovation
Trust
Do the right thing and own it!
Empathize and serve others.
Excellence
Be proud of what we do and
constantly reimagine great.
Explore and be curious.
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Our team members must refrain from illegal and unethical conduct,
and support and follow both the language and the spirit of the law.
You should be open and honest in your business relationships with
all team members and other professionals retained by Delta Dental.
Honesty requires disclosing all information that is relevant to a
given issue. You should avoid the appearance of impropriety in
conducting business; business conduct has the appearance of
impropriety if a reasonable person might conclude that the behavior
raises ethical questions.
INTRODUCTION
Delta Dental is committed to excellence and integrity
in all of our business activities. We conduct business in
a manner designed to maintain and promote the honor
associated with the Delta Dental name.
QUESTION
& ANSWER
6
Watch for these boxes
throughout this document.
These serve as roadmaps
for making ethical decisions.
We will lead you through the
thought process of making
dicult choices and help
you anticipate the potential
consequences of your
actions.
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Ethics Guide: Introduction
An article in The Ethisphere® Institute’s publication put it
best: “Whatever your view on causation, the correlation
is clear: businesses with strong governance practices,
better ethics and compliance programs, more committed
cultures and a broad engagement with their communities
have better business outcomes and higher shareholder
returns.” 1
1 A Clear Correlation: Ethical Companies Outperform, E.S. Byrne, June 9, 2017,
Do ethical
companies
perform better?
7
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Ethics Guide: Introduction
How do we ensure we are acting ethically?
In any given situation, we recognize that no set of standards or procedures can
substitute for personal integrity, good judgment and common sense. Although
expectations may be described in our policies and this Guide, this decision tree
can help you in handling dicult situations.
If you can’t comfortably answer “yes” to each of these questions, you should
stop and seek advice from your manager, Human Resources or the Department
of Risk, Ethics and Compliance.
1. Is it legal?
2. Does it comply with company policy? With this Guide?
3. Have I considered the impact to our customers, team members and the
company?
4. Would I feel comfortable explaining my actions to my colleagues, manager
and family?
5. Could I defend my actions if they appeared in a newspaper or in a social
media post?
6. Does it benefit the company as a whole, not just certain individuals?
7. If I’m unclear about something, have I asked the right person for advice?
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Ethics Guide: Introduction
This Guide applies to our team members, board of
directors and business partners. “Team members” includes
Delta Dental employees, contractors, and temporary sta,
regardless of title. “Business partners” includes providers,
vendors, brokers, consultants, subcontractors or anyone
who performs services on our behalf.
Internal policies and procedures are cited throughout this
Guide to provide additional information about internal
processes. We expect our business partners to adopt
similar policies and to act consistently with the principles
established in this Guide.
Who does this
Guide apply to?
9
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11
Ethics Guide: Raising Concerns
Reporting
It is in Delta Dental’s interest to ensure that any reports of non-compliance with this
Guide are properly investigated and acted upon in a timely fashion.
• All reports will be handled in a manner protecting the privacy of the person making
the report.
• All reports will be investigated in a timely manner, normally within 30 days of receipt.
• All reports will be investigated by people trained and experienced in conducting
investigations.
• Appropriate disciplinary action in response to substantiated allegations will occur.
Known or suspected violations of any policies associated with this Guide must be
brought to the attention of our Chief Compliance Ocer.
The eectiveness of this Guide is dependent upon our team members
complying with its guidelines, the spirit of those guidelines and the
individual judgment each team member must make when faced with their
own or others‘ decisions. To be most eective, it is also critically important
that team members report any known or suspected violations of this Guide
immediately and participate in their resolution. No one will be subject to
retaliation because of a good-faith report of suspected misconduct.
HAVE A QUESTION OR CONCERN?
Ethics Guide: Raising Concerns
In person
Talk to your manager or a Human Resources
representative: HRMailbox@delta.org
Compliance & Ethics Helpline
Call: (833)DD-REPORT or (833)337-3767
Online: www.lighthouse-services.com/deltadental
Email: reports@lighthouse-services.com
Compliance Ocer
ComplianceOcer@delta.org
Write
Delta Dental of California
560 Mission Street Suite 1300
San Francisco, CA 94105
Attn: Compliance Ocer
Questions
Contact the Department of Risk, Ethics and
Compliance with questions:
DepartmentRiskEthicsandCompliance@delta.org
There are several reporting options available to you:
12
Any report should contain the date, name of the submitter
(unless anonymous) and a summary of the alleged
violation(s). A copy of the procedure for how the report will
be handled can be found here.
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Ethics Guide: Raising Concerns
Can I report my concern
anonymously?
You can file a report anonymously
online or by calling the helpline. The
webpage is hosted by a third-party
provider, and the information you
provide will be sent to us on a totally
confidential and anonymous basis if
you choose. Similarly, the helpline is
answered by agents not aliated with
Delta Dental.
QUESTION
& ANSWER
Disciplinary Action
Delta Dental will take appropriate disciplinary
action for violations of this Guide, company policy
and/or the law, up to and including termination.
Certain violations also may be violations of the law
and could lead to individual criminal prosecution,
resulting in fines and/or imprisonment. For more
information about the company’s disciplinary
process, refer to the Workforce Discipline and
Sanctions for Compliance Violations Policy and
the Discipline Procedure. Any additional questions
about this Guide can be addressed directly to the
Department of Risk, Ethics and Compliance, the
Compliance Ocer or your manager.
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Ethics Guide: Raising Concerns
Manager Responsibilities
Managers and supervisors have leadership responsibilities
that include creating a culture of high ethical standards
and commitment to compliance, maintaining a work
environment that encourages team members to raise
ethical concerns and promptly addressing those concerns.
Managers are responsible for reporting improper conduct.
They are expected to escalate concerns, reports and
allegations. Failure to properly report issues and concerns
may result in disciplinary action. Managers must never
take or permit any retaliatory action against someone for
making a good-faith report.
Non-Retaliation/Whistleblower Protection
Please be assured you will not be subject to reprisals
of any kind for reporting violations. Delta Dental does
not tolerate retaliation or intimidation against any team
member’s good-faith participation in the compliance
and ethics program, whether that be reporting potential
issues, or participating in audits and investigations.
Delta Dental will protect team members from retaliation
and intimidation. If you believe you or someone else is
experiencing adversity or are intentionally being caused
feelings of fear or inadequacy based on issues addressed
in this Guide or otherwise, please report it to the
Compliance Ocer immediately.
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Ethics Guide: Raising Concerns
Is it okay to address an issue on my
own in order to keep a coworker from
getting in trouble?
No. If you suspect someone of
violating this Guide, you should
report it to a manager or via one
of the methods listed in this Guide.
Reporting concerns helps us learn
of dierent types of misconduct
that could occur. If concerns aren’t
reported, steps can’t be taken to
prevent misconduct from happening
in the future.
QUESTION
& ANSWER
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Ethics Guide: Raising Concerns
Waiver Provision
This Guide was duly adopted by the Board of Directors
after review and recommendation for passage by the
Audit Committee on September 6, 2018. Proposals for
amendments to this Guide will follow the same process
as for its adoption. This Guide does not explicitly cover
all conceivable situations or circumstances; however,
the Company reserves the right to apply the parameters
outlined in this Guide to situations and circumstances
arising which, in its sole discretion, fall within the spirit
and intent of the Guide.
Ethics Guide: Raising Concerns
16
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Conflicts of interest arise when a team member is associated with a competitor or
other organization. When a team member is associated with a competitor, problems
arise because the business goals of the competitor conflict with those of Delta Dental.
In addition, when a team member is associated with certain organizations, such as
regulatory agencies or dental societies, problems might arise if Delta Dental and the
other organization are not legally or ethically permitted to work together toward the
same goal — or if they have dierent or conflicting goals. A conflict of interest also arises
whenever a team member has an independent self-interest that is adverse to Delta Dental
for any reason.
Ethics Guide: Conflicts of Interest
Delta Dental considers conflicts of interest a serious matter.
Everyone assumes a basic duty of loyalty to our company.
Because of this, you should:
• Refrain from activities which may compromise that duty
• Disclose any possible conflicts of interest to Delta Dental
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QUESTION
& ANSWER
Can I sit on the board of another
company?
You should inform your manager and
contact the Legal Department to
receive guidance before accepting a
position on another company’s Board.
Things that will be considered are:
the type of company, the services
it provides and any impact it may
have on your responsibilities at Delta
Dental.
Ethics Guide: Conflicts of Interest
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Because of the potential risks and liabilities that could
arise from business circumstances impacted by a conflict
of interest, Delta Dental requires all employees, ocers
and members of the Board of Directors to disclose any
possible conflict of interest to your management. The
following are conflicts of interest that warrant disclosure
to management:
• Being in an employer-employee relationship, or other
relationship involving commitment or trust with a
competitor organization. Such organizations include,
but not limited to, entities selling or administering
dental benefit programs, including brokers and direct
competitors to Delta Dental. This conflict would also
exist if a team member had any direct financial interest,
such as stock ownership, in a competitor organization.
• Being in an employer-employee relationship, or any
other relationship involving commitment or trust, with an
organization whose interests may bear upon or converge
with those of Delta Dental. Examples include aliation
with a regulatory agency, a Delta Dental customer or
supplier, or state or local dental societies.
Ethics Guide: Conflicts of Interest
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Ethics Guide: Conflicts of Interest
• Entering into any other contract, transaction, activity,
employment or other relationship involving commitment
or trust that would impair in any way the employee's
ability to perform the duties of his or her job with Delta
Dental in good faith.
• Any other situation where the team member is in a
position to act contrary to Delta Dental’s interests.
Delta Dental considers these situations conflicts of interest
not only when they involve team members directly,
but also if a team member's spouse, domestic partner,
significant other immediate family member or relative, and
any person with whom the team member shares living
quarters, has any aliation with a competitor organization
as described above. Examples include an aliation with
a Delta Dental customer, supplier, provider or consultant,
a state agency involved in the regulation of insurance or
health-related matters, or connection to state or local
dental societies.
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22
Ethics Guide: Conflicts of Interest
Examples of companies selling dental insurance that are
in daily competition with Delta Dental include Blue Shield/
Blue Cross, Aetna, Cigna, Met Life, Prudential, UCCI,
Guardian and Travelers. Aliations such as these create
problems because Delta Dental and the other organization
may not be legally or ethically permitted to work together
toward a particular goal or to have the appearance of a
close-knit relationship.
Conflicts sometimes can arise without the design or
agreement of the team member, or organizations not
previously in conflict can later become so. Also, regardless
of whether the team member considers two particular
loyalties to be in conflict, the very appearance of the
conflict is still grounds for concern.
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Ethics Guide: Conflicts of Interest
It’s your responsibility to report an actual or potential
conflict in which you are involved to management. It is
better to try to work out a solution with management
when an actual or potential conflict arises, rather than face
possible disciplinary action for violation of the policy after
the fact. In such a situation, the fact that management was
not informed may appear purposeful, thus complicating
management's decision.
Once a potential conflict has been brought to
management’s attention, management will investigate the
matter. They will then determine whether an actual conflict
exists, and if so, develop an appropriate solution for the
circumstances of the individual case.
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Corruption may involve payment or the exchange of anything of value and includes the
following activities:
• Bribery
• Extortion
• Kickbacks
Corrupt activities not only violate this Ethics Guide; they can also violate criminal and
civil anti-bribery and anti-corruption laws. Should you become aware of any potential or
actual corrupt arrangements, speak up and report it.
Ethics Guide: Anti-Corruption
Delta Dental believes in using good judgment and integrity with every business activity
and decision and does not tolerate corruption of any kind. Corruption is defined as the
oering, giving, receiving or soliciting a personal benefit or business advantage through
improper or illegal means.
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Ethics Guide: Anti-Corruption
QUESTION
& ANSWER
QUESTION
& ANSWER
26
What is a “kickback”?
A kickback is a form of corruption
that involves two parties agreeing that
a portion of sales or profits will be
improperly given or “kicked back” to
the purchaser in exchange for making
the deal. For example, a kickback
might involve a vendor who oers a
Delta Dental team member a monthly
payment equaling 5% of Delta Dental’s
purchases as an incentive to the
team member to retain the vendor’s
services.
What is a “anything of value”?
“Anything of value” is very broad
and could include goods or services,
such as gift cards, event tickets,
entertainment, free airfare, travel
perks, use of vacation homes, special
favors or privileges, donations to
designated charities, discounts,
free personal services, financial or
property loans, or a promise of future
employment.
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Ethics Guide: Accepting Gifts
You must not directly or indirectly solicit or accept any fee, commission, entertainment,
gift, gratuity, property, discount, or loan for yourself, family members or aliates as
compensation for performing duties for Delta Dental – or making or causing Delta Dental
to make – any business decision.
You may accept reasonable business gifts of nominal value in the ordinary course of
employment, not to exceed $100. You may attend business lunches, dinners and similar
outings (e.g., sporting events, golf, theatre, shows, etc.) conducted in the normal course
of business which are neither so frequent nor so excessive as to raise any question of
propriety.
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Ethics Guide: Acccepting Gifts
QUESTION
& ANSWER
Can the gift be given openly or in a
public setting?
If not, the gift may not be
appropriate.
Do you feel obligated to give the
person your business by accepting
the gift? Are you expecting
something in return from the person
you are giving the gift to?
If so, STOP! There should be no
expectations from either party, stated
or implied, when gifts are given.
QUESTION
& ANSWER
Is the gift lavish or is it given
frequently? Gifts that are given
repeatedly can be perceived as a
conflict of interest or bribery.
If you have any doubt regarding
acceptable gift giving and/or
receiving, discuss it with your
manager or the Compliance
Ocer. Remember, if you don’t feel
comfortable, then it is likely that
accepting or giving the gift is a bad
idea.
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Ethics Guide: Giving Gifts
Except as authorized by the terms of contractual arrangements with
Delta Dental, no fee, commission, property, or any other compensation
may be oered or paid directly or indirectly by team members to, for or
on behalf of any existing or potential customer, competitor or supplier of
Delta Dental for the purpose of influencing any transactions involving or
aecting Delta Dental business.
You may provide reasonable business gifts, not to exceed $100, and may provide
business lunches, dinners and similar outings (e.g., sporting events, golf, theatre,
shows, etc.) conducted in the normal course of business which are neither so frequent
nor so excessive as to raise any question of propriety. If you are unsure that a gift is
appropriate, you should consult with your manager or the Department of Risk, Ethics
and Compliance.
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QUESTION
& ANSWER
Ethics Guide: Giving Gifts
Auditors will be on site to review
our business area. Can I oer to
take them to lunch?
There are special rules in the U.S.
that make it illegal to oer gifts
and hospitality to government
employees. Even if the auditors
are not government employees,
certain actions can be viewed as
bribery. To be safe, consult with
the Department of Risk, Ethics and
Compliance.
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• Fix prices, premiums or the terms and conditions of the products we sell
• Agree to refuse to do business with customers, providers or other competitors
• Conspire with our competitors by distributing our customers, enrollees or sales
territories in an attempt to limits open competition.
If a competitor tries to discuss prices, products or services, or the territories in which
we do business, please do not engage. We want to avoid even the appearance that
any of our pricing or business decisions are influenced by information exchanged with
competitors. Violation of these laws can lead to severe penalties, both civil and criminal,
both for team members involved and for Delta Dental. If you believe fair competition laws
have been violated, report it immediately.
Ethics Guide: Antitrust and Fair Competition
Delta Dental honors free and open competition centered on honesty and equality.
Competition laws, also known as antitrust, are designed to promote fair competition for
the benefit of consumers. To comply with competition laws, we never do the following:
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Ethics Guide: Antitrust and Fair Competition
QUESTION
& ANSWER
An individual who works for one
of our competitors approached
me and mentioned he is on a
committee that is revising the
pricing structure for some of their
insurance oerings. He wants to
know how Delta Dental handles it.
What should I say?
You should make it clear to that
person that you cannot engage
in that type of discussion. Team
members should never discuss
pricing with competitors, as this
could lead to allegations of price-
fixing or other anti-competitive
behavior.
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Such relationships have the potential to create a conflict of interest. For example, you
might have a family member who works for one of our vendors, or your former employer
might be one of several companies under consideration to become a consultant for Delta
Dental. In order to avoid even the appearance of improper behavior, you should disclose
any personal relationships of this kind immediately.
Ethics Guide: Selection and Use of Third Parties/Procurement
All business relationships with other companies should be based on their reputation for
service, integrity, quality, cost and delivery, and their ability to competitively meet our
business needs. In some cases, you may have a personal relationship with a vendor or
consultant.
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38
QUESTION
& ANSWER
Ethics Guide: Selection and Use of Third Parties/Procurement
My brother-in-law owns a consulting
firm that has a lot of expertise in a
business area we are targeting. Can I
recommend his company to work for
Delta Dental?
You can recommend your brother-
in-law’s company for consideration;
however, you must disclose your
relationship at the time you make
your recommendation. You may
not be involved in the bidding or
negotiation process, nor may you
use your position in the company
to influence those involved in the
procurement process.
HAVE A QUESTION OR CONCERN?
Ethics Guide: General Compliance with Laws and Regulations
Delta Dental is committed to conducting its business in compliance with all applicable
laws, rules and regulations. Our organization conducts business in all 50 states plus
D.C., Puerto Rico, the Virgin Islands, and Mexico and participates in federal exchanges
and federally and state-funded programs such as Medicare and Medicaid. As such, we
are subject to various state and federal laws and are accountable to those regulatory
agencies.
Our Board of Directors (BOD) has established an Audit Committee and delegated
oversight of auditing and compliance functions to this Committee. We have a designated
Chief Legal Ocer and Chief Compliance Ocer. The Compliance Ocer reports directly
to the Chief Executive Ocer (CEO) and provides unfiltered reports to the CEO and the
Audit Committee on compliance risk areas, audit and enforcement activities, strategies to
address these, and the results of these implementations.
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Ethics Guide: General Compliance with Laws and Regulations
Delta Dental has also designated an Executive Compliance
Committee (ECC) that is chaired by the Chief Compliance
Ocer and consists of senior leadership with oversight
over various operating areas. During the meetings,
compliance risk areas are discussed, including, but
not limited to, those areas that impact the Medicare
Advantage line of business. Results from these meetings
lead the ECC to advise on action plans to monitor and
control risks. When gaps are identified, we work to close
them and follow up to ensure that the modified controls
are fully implemented.
QUESTION
& ANSWER
I have a question about whether a
business process is compliant with
state law. Who should I check with?
If you question whether something
is compliant or have questions
about compliance requirements,
you should contact the Department
of Risk, Ethics and Compliance.
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Whether you have prepared a timesheet, created an expense report, or approved an
invoice, each of us contributes in some way to Delta Dental’s financial statements,
books and records. We are required to maintain and provide full, accurate, timely, and
transparent reporting of information about our company and operations. Therefore,
every business record we create and approve must be accurate, complete and reliable.
We have adopted specific practices to ensure that we make full, accurate and timely
disclosures in our filings with regulators, and comply with our obligations under the law.
Making or approving false or misleading records or documentation, or failing to properly
disclose relevant items, undermines our ability to make good decisions and is strictly
prohibited.
Ethics Guide: Accurate Books and Records
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QUESTION
& ANSWER
I'm traveling to San Francisco for
a business trip and plan to meet
an old college friend for dinner. Is
it okay if I submit the total cost of
dinner for reimbursement?
No, you may only submit your
portion of the dinner cost for
reimbursement. Since your friend
isn’t associated with our company
and the dinner is personal, rather
than business related, the total
dinner cost can’t be expensed.
Ethics Guide: Accurate Books and Records
We must never do any of the following:
• Intentionally create false or misleading entries or records
• Knowingly fail to make correct entries on any company
record or document
• Guess at an answer on a document
• Omit or conceal relevant information
The integrity of our internal controls and procedures is
only as strong as our culture of open communication and
honesty. If you have concerns about any aspect of our
financial reporting or any accounting, audit or internal
control issues, you should report them to your manager or
using any of the methods listed in the reporting section.
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Ethics Guide: Intellectual Property/ Confidential Information
Company Systems should not be used to copy, send (upload), receive (download)
or exchange copyrighted materials (e.g., that display the copyright symbol, ©, or
copyright statement), trade secrets (including, but not limited to, items marked
confidential), proprietary information (including, but not limited to, items which
include the ownership marks such as ®, ™, etc.) or similar materials except as
authorized by the owner of the material.
You should respect and protect the confidentiality of all information marked
“Confidential,” even if such information has been misdirected to you. You may not
use company systems to view or browse any employment, dental eligibility or claim
information of any employee or enrollee of the company without a legitimate company
business purpose.
For more information on protecting confidential information, Protected Health
Information, and proprietary information, please refer to our Privacy and Security policies.
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Data Privacy
Delta Dental is committed to protecting the private
information of our customers, business partners and
team members. Everyone must take appropriate actions
to mitigate risks to the privacy and security of any
confidential information to which they have access.
Confidential information is information that is restricted
to individuals whose job functions require access.
Confidential information is not made available outside of
the company without appropriate Data Owner approvals/
business agreements.
Ethics Guide: Intellectual Property/ Confidential Information
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QUESTION
& ANSWER
How do I know if I'm misusing
information?
When working with sensitive
information, ask yourself: Will my
colleagues, managers, and company
be pleased with my actions? Am I
using and accessing this information
for the correct business purpose?
If you are unsure of what to do in a
situation, you should consult your
manager.
Ethics Guide: Intellectual Property/ Confidential Information
Protected Health Information (PHI) or Personally
Identifiable Information (PII) represents subsets of
confidential information. PHI relates to the past, present,
or future physical or mental health or condition of an
individual, the provision of health care to an individual,
or the past, present or future payment for the provision
of health care to an individual. PII is information that can
be used on its own or with other information to identify,
contact, or locate a single person, or to identify an
individual in context. For more information about PHI and
PII, refer to the Privacy & Security Glossary.
HAVE A QUESTION OR CONCERN?
Ethics Guide: Intellectual Property/ Confidential Information
You should apply the following safeguard practices when
dealing with confidential information:
Minimum necessary
You may not access information you are not authorized to
view for business or legal reasons. Only communicate the
minimum amount of confidential information necessary to
accomplish the assigned task.
Awareness of place and content
When discussing confidential information, be aware of
your surroundings. Determine whether a confidential
discussion is appropriate in that environment.
Computer systems
Keep confidential information on company servers and
refrain from copying files to your desktop or saving them
on your computer’s local hard drive. When stepping away
from your computer, it must always be locked. Passwords
and other access credentials must be kept private.
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Ethics Guide: Intellectual Property/ Confidential Information
Printing
Consider your need for hard copies before printing,
and only print confidential information when absolutely
necessary. Documents should be picked up from printers
right away.
Paper materials
Confidential information should be locked up at the end of
the work day or when leaving your work area for breaks,
lunches and meetings.
Destruction
Delta Dental employs vendors to safely dispose of
confidential materials. You should use the appropriately
labeled shredding bins.
Email
When sending email, ensure that recipients’ email
addresses are correct.
For more information, refer to Delta Dental’s Protection of
Confidential Information in the Workplace Policy.
QUESTION
& ANSWER
If I find PHI at the printer, what
should I do with it?
If you know who the documents
belong to, you may deliver them
to that person. If not, discard the
documents in the nearest shred bin.
HAVE A QUESTION OR CONCERN?
Ethics Guide: Intellectual Property/ Confidential Information
Records Management
Delta Dental is also committed to eective records
management including meeting legal and operational
requirements for record retention and disposal, privacy
and confidentiality protection, optimizing the use of
space, minimizing the cost of record retention and
properly destroying outdated records. Our practice is to
assess information, designate which information to retain
as a company record, categorize it, protect it and dispose
of it at the end of the record life cycle. Information
that is of business value and reflects the decisions and
transactions of the company must be designated as a
record. At the end of the records retention period, the
records must be completely destroyed, including all
backup and duplicate copies, ensuring that information
is no longer retrievable or useable. For more information,
please refer to Delta Dental’s Record Management portal
page.
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Ethics Guide: Physical Assets
Delta Dental protects our company assets so we can better perform our jobs and serve
our customers. Delta Dental’s assets – whether they are computers, equipment, supplies,
confidential information, team member time or other physical and intellectual property –
are meant to be used for the benefit of the company.
These assets are not for personal gain or for the benefit of others outside of Delta Dental.
It is your responsibility to keep our assets safe from loss, theft, damage, inappropriate use
or other forms of abuse or fraud. If you suspect theft in the workplace, or if you become
aware of misuse of company assets, report it immediately.
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Computer Use
You are given access to computers and computer systems
to help you perform your job. Do not expect that anything
you create, store, send or receive on company owned
computers – regardless of its relation to Delta Dental
business – will be private. Without prior notice or consent,
Delta Dental may retrieve, review or disclose any material
created, stored, sent or received on its computers,
through the internet or any other computer network.
Delta Dental strictly prohibits using any of its computer
resources for any of the following:
• Sending, receiving, downloading, displaying, printing
or otherwise disseminating material that is sexually
explicit, racially oensive, profane, obscene, harassing,
fraudulent, defamatory or unlawful.
Ethics Guide: Physical Assets
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55
• Disseminating or storing destructive programs (that is,
viruses or self-replicating code), political or religious
endorsements or solicitations or any other unauthorized
material.
• Wasting computer resources by sending mass mailings,
spending excessive amounts of time on the internet,
playing games, engaging in online chat groups,
unnecessarily printing multiple copies of documents or
creating unnecessary network trac.
• Using or copying software in violation of a license
agreement or copyright. Only software properly
licensed and approved may be loaded onto Delta Dental
computers.
• Upon resignation or termination, destroying, removing,
copying or deleting any information, files or messages
stored on any Delta Dental equipment.
Ethics Guide: Physical Assets
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Ethics Guide: Physical Assets
QUESTION
& ANSWER
What are examples of misusing
company assets?
Taking oce supplies for
personal use, submitting
personal expenses on company
expense reports, falsely
reporting time worked, or
presenting false information
to receive health and disability
benefits from Delta Dental.
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Ethics Guide: Communicating with External Parties
Media and legislative inquiries may include in-person, mail, e-mail and/or telephone
communications from anyone identifying him or herself as a news reporter, journalist,
freelance writer, editor or an elected ocial, or an elected ocial’s sta member,
who requests information for any reason other than routine inquiries related to their
enrollment under a company-sponsored benefit program.
All incoming requests are to be forwarded immediately to Marketing and
Communications. This includes media and/or legislative inquiries received by any
company-aliated oce, as well as requests for interviews. For more information, please
refer to the Media Relations & Public Aairs Policy.
With the exception of Marketing and Communications sta, and designated Legal
and Senior Executive Sta, any team member interacting with a member of the media
or legislature should politely decline to comment or release any information prior to
reporting the contact to Marketing and Communications sta and receiving authorization
and direction on appropriate communications.
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59
QUESTION
& ANSWER
Could my social media
post impact Delta Dental's
reputation?
Yes. It’s best to assume that
anything you post could
become front-page news.
According to a CareerBuilder
survey, 18% of employers
have reported dismissing an
employee because of something
they posted on social media.
Social Media
On company social media pages you may show support
by “liking,” commenting in a positive way or sharing within
your own networks. On your own social media pages
(e.g., your own Facebook page, Twitter feed or Google+
page) or through your own social media activity, you may
not defame or malign team members, business practices,
products/services, vendors, customers or business
partners. You may not disclose proprietary or protected
health information (PHI) on any social media site.
Ethics Guide: Communicating with External Parties
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Ethics Guide: Communicating with External Parties
Team members who communicate on public internet
pages about Delta Dental must disclose their connection
with the company and their role, and must clearly state
that the views expressed do not represent the views of
the organization.
Marketing and Communications is responsible for
final approval of all messages and content posted on
company social media channels. Any public posting
that may jeopardize our brand or reputation should
immediately be brought to the attention of Marketing and
Communications. For more information, please refer to
the Social Media Policy.
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Ethics Guide: Communicating with External Parties
Truth in Advertising/Media
Delta Dental understands the importance of accuracy
and appropriate transparency in all internal and external
communications. The information we provide needs to be
correct and supported by our business practices.
As a regulated company, we are required to file periodic
reports with insurance departments and other agencies in
the states in which we do business. It is company policy
to make full, fair, accurate, timely and understandable
disclosures in compliance with all applicable laws and
regulations in all required reports.
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Political Activity/Lobbying
You may choose to contribute personal time and money
to political activities; however, you need to be clear and
disclose as necessary that you are acting on your own
behalf and not on behalf of Delta Dental. Delta Dental’s
name may not be used in a way that suggests the
company sponsors or endorses your personal political
activities, nor may you use your position to pressure
fellow team members to make political contributions or
support/oppose particular candidates. More generally, you
may not use any company resources (except as permitted
by Government Aairs) for political purposes.
Our Government Aairs team works to make sure
that Delta Dental has a voice in the decisions made by
government ocials. To make sure that our advocacy is
consistent, coordinated, and in compliance with laws, you
must obtain the approval of Government Aairs before
contacting government ocials on behalf of Delta Dental
about legislation, regulations, programs or policies, or
before providing any allowable gifts, meals, entertainment
or travel to a government ocial. If you have a question or
concern, report it immediately.
Ethics Guide: Communicating with External Parties
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Ethics Guide: Outside Employment
Team members with access to sensitive proprietary information are prohibited
from holding outside employment or consulting positions with other dental service
corporations, insurance companies or any organization administering dental benefits.
We recognize that any such dual employment raises potential conflicts of interest for
the team member, as well as diculties in maintaining strict confidentiality of company
information. If there are any questions as to whether a particular position is covered by
this policy, Human Resources should be contacted. For more information, refer to the
Outside Employment Policy.
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65
Ethics Guide: Outside Employment
QUESTION
& ANSWER
I received a job oer to work
at a Delta Dental oce on the
weekends. Can I accept the job?
Working in a dental oce could
mean you handle claim files, which
could be a conflict of interest.
You should inform your manager
and seek guidance from the Legal
Department before accepting the
job.
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Ethics Guide: Workplace Safety, Health and Diversity
Delta Dental firmly believes that everyone deserves the right to feel safe and
respected. When someone is subjected to inappropriate conduct that interferes with
his/her ability to perform their job, we all suer. We all have a right to work in an
environment free from violence, substance abuse and harassment.
Violence
Delta Dental is committed to providing a safe workplace for its team members. In keeping
with this commitment, we have established Workplace Security and Anti-Violence
policies that prohibit actual or threatened violence by team members against co-workers
or others. The Workplace Security policy also addresses situations in which outsiders
enter the workplace and engage in violent acts or threaten team members with violence.
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Ethics Guide: Workplace Safety, Health and Diversity
Although some kinds of violence result from societal
issues that are beyond our control, Delta Dental believes
that increased awareness and vigilance can improve the
overall security and protection of our team members.
In order to accomplish this objective, we require
the cooperation of all team members. The company
believes that team members may be better prepared to
avoid or prevent violence if they are able to recognize
early warning signs and follow appropriate response
procedures. You will therefore play a crucial role in the
administration of our anti-violence policy.
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Ethics Guide: Workplace Safety, Health and Diversity
Substance Abuse
We are firmly committed to a policy against the use
of drugs. In keeping with this commitment, we strictly
prohibit the use, transfer, possession, distribution, sale
or being under the influence of drugs or alcohol while
performing job functions, while on the company’s
premises, while operating a vehicle owned or leased
by Delta Dental, or if driving your personal vehicle on
company business.
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Ethics Guide: Workplace Safety, Health and Diversity
Harassment
We want Delta Dental to be a place where everyone feels
safe, comfortable and has the opportunity for a thriving
career. To achieve this, we must not turn a blind eye to
intimidation, harassment or abuse of power. Harassment
includes sexual harassment, but it is also any behavior
that is disruptive or upsetting and creates an environment
that is hostile and/or intimidating. Most people who are
victims of harassment don’t report it because they fear
being labeled a troublemaker, losing their jobs or believe
it will come down to their word against the other person’s.
Harassing conduct of any kind will not be tolerated. We
strongly encourage everyone to report harassment so
we can take immediate action. Managers who witness or
receive reports of harassment are required to report it. For
more information, refer to Delta Dental's Harassment policy.
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Ethics Guide: Workplace Safety, Health and Diversity
QUESTION
& ANSWER
What is sexual harassment?
Sexual harassment may consist of
unwelcome verbal, visual or physical
conduct that makes someone feel
uncomfortable. Examples include:
• Requests for sexual favors, sexual
advances or demands for dates
• Sexually oriented jokes, pictures,
text or email messages
• Explicit or degrading comments
about appearance
Does something feel wrong? Please
share your concerns. We want to
hear from you and will protect you
from retaliation.
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Ethics Guide: Workplace Safety, Health and Diversity
Armative Action/Nondiscrimination
Delta Dental recognizes and rearms the vital importance
of armative action to assure equal employment
opportunity for all. We also see this policy as ultimately
beneficial to Delta Dental as a company. We pledge to
continue a determined and sustained eort in support
of this belief and the principles in the Armative Action
policy. Delta Dental is committed to armative action
with the desired result of creating improved opportunities
for groups that have been historically excluded or
underrepresented, such as women and minorities.
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Ethics Guide: Workplace Safety, Health and Diversity
Unlawful discrimination is prohibited. It is Delta Dental’s
policy that recruiting, hiring, transfer, promotion,
termination, compensation, benefits, company-sponsored
training, education, educational assistance, social,
recreational and health programs and all layo and return-
from-layo policies are to be applied without regard to
race, color, religion, ancestry, sex, gender, gender identity/
expression, citizenship, national origin, age, sexual
orientation, marital status, veteran status, pregnancy,
physical disability, mental disability or medical condition
or any other characteristic protected by state or federal
law. Retaliation and/or intimidation as a result of reporting
violations of this policy will not be tolerated. Appropriate
disciplinary action will be taken to address violations of
this policy.
It is the responsibility of each team member, including
all members of management, to disseminate, practice
and enforce all aspects of the company policy of
nondiscrimination.
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74
QUESTION
& ANSWER
My manager frequently makes
comments about my accent and uses
oensive ethnic slurs. I'm worried
that saying something will impact my
career. What should I do?
You should report this issue
immediately. Your manager’s
behavior is inappropriate and should
be investigated. Regardless of their
intent, your manager has created a
work environment that is intimidating
and you should never fear that
your career will suer if you speak
up. Delta Dental will not tolerate
retaliation for reports made in good
faith.
Ethics Guide: Workplace Safety and Health
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Ethics Guide: Workplace Safety and Health
Labor Practices
Delta Dental supports and complies with all applicable
federal, state and local regulations that ensure safe
working conditions and equal employment opportunities
at all its locations. Delta Dental will not tolerate the use
of labor tracking, such as child labor or forced labor, in
any of its locations. The company expects our suppliers
and contractors with whom we do business to uphold the
same standards. Should a pattern of violations become
known and not corrected, we will discontinue the business
relationship.
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Ethics Guide: Corporate Social Responsibility
Corporate Social Responsibility (CSR) is important to our clients, to communities
and to our team members. CSR should not be thought of as some sort of social debt
owed by a corporation. Corporations are nothing but a collection of words on a
page, sealed with approval, until they are funded, staed and operational.
When a corporation becomes operational, its production output creates impacts in a
variety of ways, including on the environment, and both current and future generations.
Since the value that corporations bring to society also comes at a cost, corporations have
a social responsibility to give back to communities (local and otherwise) that support that
corporation’s existence and good fortune. CSR, therefore, provides a platform for Delta
Dental to conduct itself as a model corporate citizen, and give back to its communities in
ways that complement Delta Dental’s interests and are in support of its purpose, mission
and values.
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QUESTION
& ANSWER
Ethics Guide: Corporate Social Responsibility
How can I get involved and share
my ideas?
• Do you see anything we
could be doing better to “go
green?” Send your ideas to
GoingGreen@delta.org.
• Interested in volunteer
opportunities? Visit the
volunteer page on the portal.
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79
Ethics Guide: Corporate Social Responsibility
Delta Dental’s CSR program rests on four conceptual
elements that build on each other:
• Economic responsibility is ensuring that our company
is financially healthy. This encompasses strategies
that ensure our financial viability while also returning
social value. You are empowered to look for ways to
improve our value chain.
• Legal responsibility is acting economically
responsible and following all applicable laws and
regulations. All team members play an integral role in
ensuring legal compliance.
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Ethics Guide: Corporate Social Responsibility
• Ethical responsibility is ensuring we’re following this
Guide and doing the right thing morally as we fulfill
our economic and legal responsibilities. We promote
employee welfare with competitive wages and benefits,
and we promote workforce diversity and wage equality.
We’re also environmentally conscious in terms of taking
steps to reduce our environmental impact.
• Philanthropic responsibility is ensuring that while we’re
economically, legally and ethically responsible, we
also go beyond what is required in terms of benefiting
society. We give back to our communities through our
foundation, direct corporate gifts, scholarships, matching
employee donations, and through our volunteer
program.
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81
Ethics Guide: Corporate Social Responsibility
These concepts are part of the larger concept of
corporate social responsibility — our impact on
environmental and social well-being. Each team member
is responsible for supporting these concepts and are
encouraged to seek ways to contribute to the success of
the CSR program. For more information on Delta Dental’s
CSR eorts, visit the Community Center section on our
corporate website.
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NOTES
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NOTES
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