Compliance Program

Palladian Muscular Skeletal Health firmly believes that a company’s commitment to legal and ethical business practices should form the core of its values.

To assure that every employee understands what is expected, and to permit the Company to monitor compliance and ethics, Palladian has adopted a Corporate Compliance Program. 

The Compliance Program has several components.  First, the Board of Managers (“Board”) is responsible for ensuring that the Company adopts and maintains a Compliance Program that meets the standards set for healthcare organizations and government contractors and for providing oversight of the Program.  Second, to carry out the day-to-day operation of the Program, the Company has appointed a Compliance Officer, whose duties include providing Ethics and Compliance training, responding to compliance questions raised by Company personnel, and, together with the General Counsel, investigating and addressing reports of misconduct.  Among other duties, the ComplianceOfficer also is responsible for monitoring the success of the Program and for making changes to the Program as needed, including enhanced employee training, updates to written policies and procedures, and commissioning internal and external audits of Company operations. 

In addition, the Company has distributed along with explanatory training, a Code of Conduct and Business Ethics (“the Code”).  From time to time, to supplement the Code, the Company will issue written policies and guidelines relating to particular legal, regulatory, and contractual requirements, including those special rules under which the Company operates as a contractor to the Federal Government, as well as state and local governments.  The Code is available to all Company employees, consultants, and agents.  Employees, consultants, and agents are expected to certify that they have read the Code, and managers and supervisors are required to annually certify that they have discussed the Code with employees during performance evaluations.

Finally, the Company has an internal reporting system for employees to report ethics and compliance concerns and suspected violations of the Code.  In particular, the Company has instituted a toll-free Helpline to permit employees to raise questions or report misconduct, anonymously if they choose.  The Helpline is answered by the Compliance Officer or calls will go to a secure voice mailbox that can be accessed only by the Compliance Officer.  If an employee requests anonymity, every reasonable effort will be made to protect the identity of the caller.  If an employeehas a concern about reporting an issue to the Compliance Officer, the employee may take the issue to the Human Resources Manager or the General Counsel.