Vendor Code of Conduct

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You have the ability to report anonymously using the Compliance Hotline: 

Legacy Compliance Hotline: 1-800-820-7478


A Message from Legacy Health Leadership

Legacy Health is committed to providing good health for our people, patients, communities, and our world. Our vendors and business partners play a vital role in helping us achieve our mission. This Vendor Code of Conduct establishes Legacy’s standards for excellence, integrity, and ethical business practices for all vendors, suppliers, contractors, and consultants. Vendors are expected to uphold these standards and support a culture of quality, compliance, safety, and respect in every interaction with Legacy Health.


Legacy Health Mission and Values

Mission

Our legacy is good health for:

  • Our people
  • Our patients
  • Our communities
  • Our world

Above all, we do the right thing.

Values

We expect our vendors to demonstrate:

  • Respect: Treat all people with dignity, compassion, and inclusion.
  • Service: Put the needs of patients and families first.
  • Quality: Deliver outstanding services and products.
  • Excellence: Uphold high ethical standards.
  • Responsibility: Steward resources responsibly.
  • Innovation: Seek opportunities for improvement.
  • Leadership: Model good citizenship and health.

Why Do We Have a Vendor Code of Conduct?

Healthcare is complex and highly regulated. Vendors must comply with all applicable laws, regulations, and Legacy Health policies. This Code provides guidance for ethical decision-making and helps vendors build honest, trusting relationships with Legacy Health and the communities we serve.


Does the Vendor Code of Conduct Apply to Me?

This Code applies to all vendors, suppliers, contractors, consultants, and their representatives who provide products or services to Legacy Health. Vendors must ensure their employees, agents, and subcontractors understand and comply with this Code.


How Should Vendors Use the Code of Conduct?

Vendors should use this Code to guide their actions and decisions when working with Legacy Health. Key questions to consider:

  • Are my actions consistent with Legacy’s mission and values?
  • Am I following all applicable laws, regulations, and Legacy policies?
  • Am I acting with integrity and accountability?
  • Do I know how to report a potential compliance concern?

Key Standards for Vendors

Legal and Regulatory Compliance

  • Comply with all federal, state, and local laws, including anti-kickback statutes, Stark, False Claims Act, HIPAA, and other healthcare regulations.
  • Ensure all personnel are properly licensed and not excluded, suspended, debarred or otherwise ineligible to participate in federal healthcare programs (e.g., Medicare).

Conflicts of Interest

  • Avoid activities or relationships that could impair judgment or create a conflict between vendor interests and Legacy Health’s interests.
  • You must disclose any actual or potential conflicts of interest to Legacy Health promptly.
  • Physician-owned distributorships are prohibited. Vendors must disclose any physician or immediate family ownership interests for Legacy Health review.
  • Arrangements intended to influence patient referrals are strictly forbidden.

Gifts, Gratuities, and Business Courtesies

  • Do not offer gifts, entertainment, or business courtesies to Legacy Health employees as this could influence or appear to influence business decisions.
  • Only unsolicited gifts of nominal value (≤$75 per year per recipient) may be accepted, in accordance with Legacy policy. This includes business meals and related entertainment. Cash or cash equivalents are strictly prohibited.
  • Product samples may not be provided without the advance review and approval of Legacy Health Supply Chain Management.

Vendor-Paid Travel, Honoraria, and Speaker Fees

  • Do not offer travel, honoraria, or speaker fees to Legacy Health employees for activities related to their work at Legacy, except as explicitly permitted by Legacy policy and with appropriate approvals. Speak with Supply Chain Solutions or Corporate Compliance for more information.
  • Any approved travel, sponsorship or other payments will not be approved if within 6 months of contract award, termination or renewal.

Safeguarding Legacy Assets

  • Protect Legacy Health’s assets, including confidential information, intellectual property, and physical resources.
  • Use Legacy assets only for authorized business purposes.

Confidentiality and Privacy

  • Protect the confidentiality and privacy of patient, employee, and business information.
  • Access protected health information (PHI) only as required for contracted services and in compliance with HIPAA and Legacy policies.

Integrity and Accuracy of Records

  • Maintain honest and accurate business records.
  • Do not submit false, misleading, or artificial information to Legacy Health.

Quality, Safety, and Compliance Reporting

  • Deliver products and services that meet Legacy’s quality and safety standards.
  • Report any compliance concerns, suspected fraud, or unethical conduct to Legacy Health promptly.

Workplace Conduct and Safety

  • Maintain a safe, respectful, and harassment-free environment when on Legacy premises.
  • Comply with Legacy’s safety, security, and infection control policies.
  • Vendor must follow the visitor and vendor access policies including the use of Green Security for sales representatives coming on-site. Wearing the appropriate badging and having an approved appointment are requirements of these policies.

Interactions with Regulatory Authorities and Government Officials

  • Do not offer gifts or anything of value to government officials or regulatory authorities.
  • Conduct all interactions with government representatives with integrity and in compliance with applicable laws.

Political Activities and Donations

  • Do not use Legacy Health’s name, resources, or property for political activities or donations.Vendor may not participate in a fundraiser event (e.g., sponsorship) within 6 months of their contract end-date or during any RFP (request for proposal) event. 

Endorsements

  • Do not use Legacy’s name or logo in any advertising, publicity, training materials or other materials, indicating that Legacy is a customer or as an endorsement that we may use your product or services without written permission from Legacy.
  • Vendors seeking to interview a Legacy employee or receive a reference regarding their products or services must obtain written permission.

Environmental and Social Responsibility

  • Support Legacy’s commitment to environmental stewardship and community engagement.
  • Do not discriminate based on race, religion, gender, sexual orientation, national origin, age, disability, or any other protected status.

Reporting a Compliance Concern

If you see or suspect a violation of this Code, regulations, or laws, you must speak up. Vendors may report concerns to their Legacy Health representative, the Compliance Officer (complianceofficer@lhs.org), or call the Compliance Hotline at 1-800-820-7478. Reports may be made anonymously and retaliation for good faith reporting is strictly prohibited.

Definitions of Special Terms

  • Vendor: Any party (e.g., supplier, contractor, consultant) from which Legacy Health acquires or may acquire materials or services.
  • Conflict of Interest: Any situation where outside activities or personal interests influence, or appear to influence, objective decision-making.
  • Business Courtesy: Anything of value, a favor, or benefit provided free of charge or at less than fair market value.
  • Confidential Information: Patient, employee, volunteer, proprietary, or quality information in any form.
  • Protected Health Information (PHI): Individually identifiable health information protected by law.