Code of Conduct

Vault Medical Group

MISSION:

To accelerate better health outcomes through faster diagnosis, innovative clinical research, and digital-first care delivery.

For general compliance questions, contact Vault’s Compliance Office at [email protected].

To report potential non-compliance or another concern, contact Vault’s Speak Up Hotline at 844-965-3497 or visit vaulthealth.ethicspoint.com to file a report online.

A Letter From Our Chief Clinical Officer

Dear Colleagues, Since its inception, Vault has strived to maintain an innovative, people-centric culture in its mission to accelerate better health outcomes. Vault has quickly become a trusted provider of healthcare, diagnostic testing, clinical research, and digital-rst patient care. While our services may continue to evolve, we remain committed to delivering quality care. Providing superior services requires hiring and retaining excellent individuals who embody our Leadership Principles every day. Every day, businesses, governments, and patients across the United States trust us with their most valuable asset -- their health. Together, we are delivering care to patients on their terms, virtually or physically. I hope you feel proud of the role you play every day in reaching our goals- because I know I do. At Vault, we are proud to hold ourselves to the highest standards when it comes to treating one another with respect and in an appropriate manner. The decisions we make affect and reflect upon all of us at Vault– collectively, our actions make us what we are. On behalf of the Executive Leadership Team, you have our commitment to acting ethically and responsibly, and we ask the same of you. We are a team and we must operate with integrity and transparency in order to succeed. This is why we created the following Code of Conduct ("Code"). This Code adopted by Vault Medical Group (“Vault" or the “Company") is your guide to appropriate behavior so we can do things right, every time. We must set high expectations and with your help, we can meet our legal and regulatory obligations, continue growing our exceptional team, and welcome and respect every patient, partner, provider, and employee. As used in this Code, “Personnel” includes all Vault people leaders, employees, contractors, and subcontractors. This Code will be distributed to all Personnel upon hire, and Personnel must sign an acknowledgement that they have received, read, understand, and will follow these standards. Vault people leaders are responsible for ensuring that all Personnel under their supervision understand the standards of conduct and comply with them, as well as with all Company policies and procedures. Violating the provisions of the Code may also be violating the law. Such violations could subject the Company, and the individuals involved, to civil and/or criminal penalties, private lawsuits, reputational harm, and loss of customers. Any Personnel who violate the Code will be subject to disciplinary action, up to and including termination of employment or contract or removal from leadership. If you are unclear if a particular action would violate the Code, ask your manager or contact the Compliance Office. Thank you for your commitment to our Leadership Principles and this Code. We are thrilled that you are part of the Vault team and look forward to doing great things together.

signature.png

Alexander Pastuszak, M.D., Ph.D.

Chief Clinical Officer

1. Our Leadership Principles

Vault is committed to fostering a diverse, equal, and inclusive work environment. From our hiring practices to providing equal and fair treatment for all team members, we are all responsible for ensuring a safe and effective environment. At Vault, all team members should feel valued and have the opportunity to fully participate in creating success for our business.

Our Leadership Principles guide us daily in all our projects. By following these Principles and this Code, you help make Vault a great place to work!

Do the right thing

Do the right thing

Leaders are right a lot. They have strong judgment and good instincts. They seek diverse perspectives and work to disconfirm their beliefs.

Earn relationships

Earn relationships

Leaders listen attentively, speak candidly, and treat others respectfully. They are vocally self-critical, even when doing so is awkward or embarrassing. Leaders do not believe their or their team’s body odor smells of perfume.

Deliver fast & simple

Deliver fast & simple

Leaders focus on the key inputs for their business and deliver them with the right quality and in a timely fashion. They are not limited by “not invented here” syndrome and always find ways to simplify.

Customer obsession

Customer obsession

Leaders start with the patient and work backwards. They work relentlessly to earn and keep patient trust. Although leaders pay attention to competitors, they obsess over patients.

Lead with data

Lead with data

Leaders operate at all levels, stay connected to the details, audit frequently, and are skeptical when meterics and anecdotes differ. No task is beneath them.

Disagree & commit

Disagree & commit

Leaders are obligated to respectfully challenge decisions when they disagree, even when it's uncomfortable or exhausting. With conviction and tenacity, they do not compromise for the sake of social cohesion. Once a decision is determined, leaders fully commit.

Drive excellence

Drive excellence

Leaders have relentlessly high standards, always raising the bar to deliver high quality products, services, and processes. Leaders ensure defects do not get sent down the line and problems are fixed so they stay fixed.

Hire and develop the best

Hire and develop the best

Leaders raise the performance bar with every hire and promotion. They recognize exceptional talent and take their role in coaching others seriously.

Own it

Own it

Leaders are owners. They think long term and don't sacrifice long-term value for short-term results. They act on behalf of the entire company, beyond just their own team. They never say "that's not my job."

Think big

Think big

Thinking small is a self-fulfilling prophecy. Leaders create and communicate a bold direction that inspires results. They think differently and look around corners for ways to serve patients.

Frugality

Frugality

Invest wisely, accomplishing more with less. Constraints breed resourcefulness and invention. No extra points for growing headcount, budget size, or fixed expense.

2. The Basics

Vault requires all Personnel to comply with this Code. Conduct not specifically addressed by this Code must be consistent with the policies within it. You are required to cooperate with internal investigations conducted by the People Team, Compliance Office, Internal Audit, or the Legal Department in relation to this Code or any other obligations or policies that apply to Personnel. 

Violating the provisions of this Code can also be violating the law. Such violations could subject the Company and the individuals involved to civil and/or criminal penalties, private lawsuits, reputational harm, and loss of customers. If you violate this Code, you may be subject to disciplinary action, up to and including termination of employment or contract or removal as an officer or director. If it is unclear if a particular action would violate the Code, contact the Compliance Office. 

Nothing in this Code of Conduct is intended to nor may be construed as providing any additional employment or contract rights to Personnel or other persons. 

While the Company will attempt to communicate changes as soon as possible, the Company reserves the right to modify, amend, or alter the Code of Conduct without prior notice to any person or Personnel. 

Vault will strive to ensure that all activity by or on behalf of Vault is in compliance with all applicable international, federal, and state laws. 

The following sections are intended to provide guidance to help you comply with applicable laws. You are required to comply with all applicable laws, whether or not specifically addressed in this Code or other policies. If questions regarding the existence, interpretation, or application of any law(s) arise, contact the Compliance Office or the Legal Team.

3. Speak Up: Reports & Investigations

Personnel are obligated to report known or suspected violations of this Code, the Company’s Compliance Plan, compliance policies, or federal, state, or local laws. We must all work together to ensure a safe, effective, and compliant environment. If you see or suspect a violation of this Code, you must immediately report the issue:

  • to your immediate supervisor, 

  • anonymously to the Company’s reporting hotline, 

  • to the Compliance Office, or 

  • directly to the Chief Compliance Officer, the Chief People Officer, the General Counsel, or any member of the Executive Leadership Team. 

What We Do With The Report

If you make a good faith report of a known or suspected violation of the Code, compliance policies or any other laws, rules, or regulations, your identity will be kept confidential to the extent permitted by law, unless doing so prevents a full and effective investigation of the reported concern. Personnel involved in the investigation of, or response to, reported compliance concerns are bound by a strict policy of confidentiality. 

Non-Retaliation (Whistleblower) Policy 

The Company maintains a strict non-retaliation policy. You will never be subject to retaliation or punishment for submitting a good faith report of suspected non-compliance with this Code, a healthcare law or regulation, or other applicable policy. If you act in good faith and with a reasonable belief that the information you are providing is true, the Company will investigate and take all claims of non-compliance, including allegations of retaliation, seriously. Retaliation is grounds for disciplinary action, up to and including termination of employment or contract and appropriate legal action. 

Auditing and Monitoring 

The Company reserves the right to monitor compliance with this Code. Monitoring may be conducted through audits or inspections that may take place without prior notice to Personnel. Personnel must provide representatives from the Company with access to relevant facilities, documents, records, and employees upon request for the purpose of an audit. 

4.  How We Work Together 

Vault expects Personnel to treat all individuals with respect at all times. Employees are encouraged to remember the golden rule: treat others how you want to be treated! 

Non-Discrimination 

Vault believes that the fair and equitable treatment of Personnel, affiliated providers, Study participants, and patients are critical to fulfilling its vision and goals. We provide our services to individuals without regard to race, color, religion, sex, ethnic origin, age, or disability of such person, or any other classification prohibited by law. 

It is our policy to provide equal treatment to all Personnel and applicants for employment regardless of race, sex, age, creed, color, religion, national origin, disability, sexual orientation, gender identity, pregnancy, veteran status, or any other classification prohibited by law. This policy applies to all aspects of employment— recruitment, selection, job assignment, promotion, transfer, reduction in force, recall, compensation, discipline, termination, and access to benefits and training. 

Harassment and Bullying 

Vault does not tolerate any form of sexual or other harassment or bullying in the workplace by any Personnel, whether they are a Vault employee, contractor, or vendor/vendor employees. This includes but is not limited to, insulting or degrading remarks or conduct, offensive or derogatory jokes, bullying, or conduct that creates an intimidating or hostile work environment. This includes not only conduct based on an individual’s sex or gender, but also conduct based on any other characteristic protected by law, including but not limited to, race, color, religion, national origin, age, pregnancy, sexual orientation, gender identity, genetic information, disability, military status, or veteran status. 

People in leadership positions may not threaten or insinuate that an employee’s refusal to submit to sexual advances will adversely affect the employee’s continued employment, compensation, performance evaluations, advancement, assigned duties, or any other condition of employment.

If you feel you been subjected to any form of workplace harassment or bullying or have witnessed any form or workplace harassment or bullying, you must promptly report the incident: 

  • to your immediate supervisor; 

  • anonymously to Vault’s reporting hotline; or 

  • directly to the Chief People Officer, any People Operations Business Partner, or any member of the Executive Leadership Team. If you are a people leader and you receive a complaint of workplace harassment, you must promptly contact the People Operations Team. Retaliation or discrimination against any person for making a complaint of workplace harassment or assisting in an investigation is strictly prohibited. Any form of harassment or discrimination, or retaliation for reporting harassment or discrimination, will be grounds for disciplinary action, including, but not limited to, immediate termination of employment or contract. 

Personal Relationships

Vault discourages dating or intimate relationships between a member of leadership and their subordinates. Even if the relationship is voluntary and welcome by both parties, you may not maintain a dating or intimate relationship with an employee or contractor if the employee or contractor works directly or indirectly for you or if you have compensation, performance review, or promotional input with respect to the employee or contractor. If you are a leader in a dating or intimate relationship with a subordinate, you must promptly inform your immediate supervisor and the People Operations Team so that appropriate steps can be taken to end the reporting relationship. Anyone failing to report a dating or intimate relationship with a subordinate may be subject to disciplinary action, up to and including termination of employment or contract. 

5. How We Keep You Safe 

Background and Exclusion Screenings 

Vault does not contract with, employ, or bill for services rendered by an individual or entity that is excluded or ineligible to participate in federal or state healthcare programs, suspended or debarred from federal government contracts, or that has not been reinstated after a period of exclusion, suspension, debarment, or ineligibility. Vault regularly searches the Department of Health and Human Services, Office of Inspector General, General Services Administration, and applicable state lists to identify such excluded and ineligible persons and entities. If you become excluded, debarred, or ineligible to participate in federal or state healthcare programs, you are required to report this change in status to the Compliance Office immediately. 

Preventing Workplace Violence 

We should all be able to work in an environment free from violence and threats of violence. The Company will not tolerate any act of workplace violence on Company property or using Company assets by any individual. If you are aware of a workplace violence incident or a potential threat, you must immediately report such acts or situations to your immediate supervisor, the People Operations Team, or the Compliance Office. 

Drug-Free Work Environment 

Vault maintains a drug-free work environment. You must comply with all laws prohibiting or controlling the manufacture, sale, distribution, use, and possession of drugs and alcohol, particularly when on Vault or client premises or while on Company business. Reporting to work while impaired by, or otherwise under the influence of, drugs or alcohol is prohibited and is grounds for disciplinary action, up to and including termination of employment or contract. 

Environment, Health, and Safety 

Vault is committed to engaging in environmentally sound practices and complying with all applicable environmental, health, and safety laws in all geographic areas in which we conduct business. Business operations must be conducted in a manner that protects the natural environment and human health and safety, including compliance with all laws and standards protecting the safety of patients, Good Clinical Practices and other laws protecting human participants in clinical studies. 

Vault’s physical locations must comply with all environmental and health and safety laws, regulations, rules, policies, and practices to ensure workplace health and safety. The Company is committed to protecting employees from potential workplace hazards. You are required to be familiar with these requirements and understand how they apply to your job responsibilities. You must seek advice from your supervisor whenever you have a question or concern. You must immediately advise your supervisor of any serious workplace injury or any situation presenting a danger of injury. Additionally, all injuries must be reported to the People Operations team as soon as reasonably possible.

6. How We Act With Integrity 

In furtherance of Vault’s commitment to the highest standards of business ethics and integrity, Personnel will accurately and honestly represent Vault and will not engage in any activity or scheme intended to defraud anyone of money, property, or honest services. 

Honest Communication 

Vault requires candor and honesty from Personnel in all communications. The Company will strive to provide timely and accurate information to patients and Personnel. You are prohibited from making false or misleading statements to any patient, person or entity doing business with Vault. 

Financial Transactions and Reporting 

Vault’s books and records must be kept in accordance with Generally Accepted Accounting Practices (“GAAP”). All transactions, payments, receipts, accounts, and assets will be completely and accurately recorded. No payment will be approved, made, or requested with the intention or understanding that it will be used for any other purpose other than that described in the supporting documentation of the payment. 

All financial reports, accounting records, expense reports, timesheets, and other documents must accurately and clearly represent the relevant facts or the true nature of a transaction. Improper or fraudulent accounting, documentation, or financial reporting is contrary to Company policy and may be in violation of applicable laws. 

Accuracy, Retention and Disposal of Documents and Records 

Personnel are responsible for the integrity and accuracy of the Company’s documents and records. No one may alter or falsify information on any record or document. Patient, clinical research and business records will be maintained and retained in accordance with the law and Company policies and procedures, and failure to do so is grounds for disciplinary action, up to and including termination of employment/contract. 

7. How We Comply With Healthcare Laws 

The business of healthcare is heavily regulated. Our business transactions with vendors, contractors, and other third parties must be free from offers or solicitation of gifts, favors and other improper inducements in exchange for influence or assistance in a transaction. 

It is the intent of Vault that this policy be construed broadly to avoid even the appearance of improper activity. If you have any doubt or concern about whether specific conduct or activities are ethical or otherwise appropriate, contact the Compliance Office. 

Antitrust Laws 

All Personnel must comply with applicable antitrust laws and similar laws that protect competition. As part of this requirement, when conducting business on behalf of Vault, you are expected to: 

  • conduct yourself in a fair and transparent manner, 

  • make appropriate decisions based on the Company’s best interests, 

  • compete on the basis of quality, innovation, and efficiency, and 

  • be generally aware of what the antitrust laws permit and prohibit. Examples of conduct prohibited by the antitrust laws include express or implied agreements among competitors and potential competitors to: 

  • fix prices, discounts, or other key terms affecting prices offered to customers; 

  • improperly coordinate on RFP responses and bid submissions; 

  • allocate business opportunities, customers territories, sectors of the market, or services; 

  • boycott suppliers or customers or otherwise take actions that harm upstream or downstream competition; 

  • improperly coordinate wages/compensation or hiring/recruitment; or 

  • fix prices, discounts, or other key terms affecting pricing and reimbursement. To avoid antitrust violations, or even the appearance of improper conduct, you must seek guidance from the Legal Team before requesting or exchanging competitively sensitive information. Such information includes pricing information, forward-looking marketing or strategic planning information, wage/benefit information, margin and cost information, or other confidential or proprietary information. You are expected to seek advice from the Legal Team when considering any collaboration, joint bid scenario, or other initiative involving a competitor or potential competitor. Additionally, you must contact the Legal Team as soon as possible if you become aware of a potential antitrust violation by Personnel or a third party. 

Anti-Kickback Statute and Fraud and Abuse 

Many business arrangements that are legal (even encouraged!) in other industries are illegal in the healthcare industry. 

The federal Anti-Kickback Statute prohibits Personnel and their families from receiving personal kickbacks or rebates as a result of Vault’s purchase or sale of goods or services. Kickbacks and other illegal payments can be in the form of cash, services, gifts, goods, entertainment, facilities, appreciation of stock, or any other items of value, including small gifts or items, intended to induce the referral of patients, items, or services covered by Medicare, Medicaid, or another government-funded program. Any kickback, bribe, or rebate made or received can result in severe civil and criminal penalties, significant monetary fines, exclusion from the Medicaid, Medicare, or other government-funded program, and/or imprisonment. Personnel involved in kickbacks or illegal payments will be subject to disciplinary action, including termination of contract/employment. 

Stark Law and Physician Self Referrals 

The federal physician self-referral law, referred to as the Stark Law, prohibits a physician from making referrals to an entity or submitting a claim for the furnishing of “designated health services” payable under Medicare or Medicaid, if the physician or an immediate family member has a financial relationship with the entity, unless certain exceptions are met. 

Billing and Coding (False Claims Act) 

Personnel have a responsibility to oversee and monitor the accuracy and integrity of claims submitted on the Company’s behalf. If you notice or suspect that a claim is inaccurate or fraudulent, you have a responsibility to take steps to remedy the issue. The Company’s policy is to require by contract that its third-party billing companies comply with this Code of Conduct. 

Federal law prohibits anyone from making or presenting a claim for payment to the United States or any of its agents if that person or entity knew or should have known the claim was false, fictitious, or fraudulent. Any false, fictitious, or fraudulent claim made in the course of seeking reimbursement under Medicare, Medicaid, or any government-funded program may result in severe civil and criminal penalties, including imprisonment, monetary fines, and exclusion from the government program. 

False claims include those for services that were not performed. In no event may Personnel submit any claims for reimbursement or receive reimbursement for products or services that have not actually been delivered or performed. Further, Personnel must provide and maintain accurate and complete and proper documentation, including proper diagnostic codes and other necessary documentation in sufficient detail, clarity, and legibility to support the medical necessity of items or services. 

If you submit a false, fictitious, or fraudulent claim or statement to any payer when you know or should have known that the claim is improper, you will be subject to disciplinary action, up to and including termination, and you may expose yourself, the Company, and other Personnel to severe civil and criminal penalties. 

8. How We Prevent Conflicts of Interest 

Personnel must base business decisions and actions on the best interests of Vault. Personnel may not use their position at Vault to profit personally or to assist others in profiting in any way at the expense of the organization. 

Personnel are expected to identify and avoid situations and interactions with others that are, or may appear to be, a conflict of interest. A conflict of interest occurs when an individual’s personal interest interferes in any way – or even appears to interfere – with the interests of the Company as a whole. All apparent, potential, and actual conflicts of interest must be carefully avoided. 

Services for Competitors and Vendors 

You may not perform work or render services for any competitor of the Company, or for any organization with which the Company does business or that seeks to do business with the Company, outside of the normal course of your employment or contract with the Company, without written approval from the Company. Further, you are prohibited from serving as a director, officer, or consultant of such an entity, and from allowing your name to be used in any fashion that would indicate a business connection with such entity, without obtaining prior written approval from the Compliance Office. 

Participation on Boards of Directors and Trustees 

You must obtain approval from Vault prior to serving as a member of the Board of Directors or Trustees of any organization whose interests conflict or appear to conflict with those of Vault. If you are asked or seek to serve on the Board of Directors or Trustees of any organization whose interest would not impact Vault (for example, non-governmental, charitable, and fraternal), you are not required to obtain such approval. However, you must disclose such service under the Conflict of Interest Policy. Vault retains the right to prohibit service on any Board of Directors or Trustees if such service might conflict with the best interests of Vault. 

Honoraria 

Vault Personnel are encouraged to participate as faculty and speakers at educational programs and functions. Unless a faculty position is already approved by the Company, and in compliance with the Conflict of Interest Policy, you must obtain written approval from the Company prior to accepting a speaking opportunity. 

9. How We Keep Information Safe 

During the course of your work for Vault, you will have access to different types of confidential, sensitive, and proprietary information. You are responsible for using and disclosing this information only as allowed by law, our contractual commitments, and Vault policies. 

Employee Information 

Vault respects employees’ privacy and treats individuals’ personal information (e.g., contact and family information, medical records, compensation and performance data, and Social Security numbers) with great care and in accordance with all applicable laws. Employee files, payroll information, disciplinary matters, and similar information will be maintained in a manner designed to ensure confidentiality in accordance with applicable laws and internal policies and procedures. Employee files are accessed only by authorized individuals and used only for legitimate business purposes. Personal information will not be disclosed to outside organizations except as permitted by law or in conjunction with administration of the Company’s benefit programs. The employee must provide written authorization before their information will be released. 

Patient and Subject Information 

All Personnel have an obligation to maintain the confidentiality of patient protected health information in accordance with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) as well as any applicable state privacy and security laws and regulations. You are prohibited from accessing or disclosing any patient information unless authorized to do so. Any disclosure of protected health information must be limited to the minimum necessary to accomplish the task. If you have questions regarding your obligation to maintain the confidentiality of information or whether you can disclose certain information, refer to Vault’s HIPAA policies and procedures or contact the Compliance Office. 

Proprietary Information 

Non-public information, ideas, and intellectual property assets belonging to Vault are important to organizational success and are considered “proprietary”. Information pertaining to the Company’s competitive position or business strategies, payment, pricing, and reimbursement information, research, databases, customer and supplier lists, and information relating to negotiations with Personnel or third parties must be protected and may be shared only with Personnel who need to know such information to perform their job responsibilities. 

Confidential or proprietary information belonging to another person or entity must be handled with care. You must handle confidential or proprietary information in accordance with all laws, regulations, Company or third party policies, and mutual non-disclosure agreements, as applicable. You agree that you will not utilize any publication, electronic data, document, computer program, information, or product in violation of Vault’s or a third party’s interest in such product. You must not improperly copy documents or computer programs for your own use in violation of applicable copyright laws or licensing agreements. Unauthorized use or distribution of proprietary information violates Company policy and could be illegal. Such use or distribution could result in negative consequences for both the Company and the individuals involved, including potential legal and disciplinary actions. If you have questions about this requirement, contact the Legal Team.

Client, Contractor and Business Partner Information 

Vault respects the privacy of our client, contractor and business partner information and actively protects that information. Our clients and business partners trust us with their data and we must keep the data safe, secure, private, and confidential. Any disclosure of confidential information must be authorized and limited to the minimum necessary to accomplish the task. 

If questions arise regarding your obligation to maintain the confidentiality of information or the appropriateness of disclosing information, contact the Compliance Office for further guidance. 

Intellectual Property 

Vault respects the intellectual property owned by others and permits the use of copyrighted or trademarked materials only as allowed by law or in accordance with a license or other agreement. You must never make copies, resell, or transfer software or its supporting documentation unless you are authorized to do so. If you have questions about intellectual property expectations and allowed usage, contact the Legal Team for guidance. 

10. How We Interact With Third Parties 

Lobbying and Political Contributions 

Activities such as meeting with government officials or employees to discuss business opportunities or issues of importance to the Company can be regulated lobbying activity. You must obtain prior approval from the Compliance Office or Legal Team for any work activity that may require lobbying communication with any member or employee of a legislative body or with any government official or employee in the formulation of legislation. This includes meetings with legislators, members of their staff, or meetings with senior executive branch officials on behalf of the Company. 

The Company reserves the right to communicate its position on important issues to elected representatives and other government officials. It is the Company’s policy to comply fully with all local, state, federal, foreign, and other applicable laws, rules, and regulations regarding political contributions. 

Gifts and Entertainment to Government Officials 

Personnel are prohibited from offering any payment or business amenity of any value to any public official or government employee. 

Personnel are responsible for fully complying with all applicable anti-bribery laws, including but not limited to the Foreign Corrupt Practices Act (“FCPA”) which makes it illegal to offer, pay, promise to pay, or authorize to pay any money, gift, or other item of value to any foreign official, political party, or candidate to assist the Company or another to obtain or retain business. All leaders are expected to monitor continued compliance with the FCPA. 

If you have any questions about this policy, please, contact the Compliance Office or Legal Team. 

Communications with Third Parties 

You must immediately notify the Legal Team if you become aware of any commenced, threatened, or anticipated investigation, audit, or other inquiry, whether by the government or a private party, or upon the service of legal process. The Legal Team will promptly notify Personnel known to be in possession of potentially relevant documents and direct them to stop the destruction of any relevant documents pending further notice that the investigation or litigation has concluded. 

11. How You May Use Company Assets 

All Personnel will strive to preserve and protect the Company’s assets by making prudent and effective use of Vault resources and properly and accurately reporting expenses. 

All Personnel are expected to refrain from using Vault assets for personal business. All property and business of the organization must be conducted in a manner designed to further the Company’s interest rather than your personal interest or that of another individual employee. You are prohibited from the unauthorized use or taking of Company equipment, supplies, materials, or services. Prior to engaging in any activity on Company time that will result in any expense to the Company or the use of the Company’s equipment, supplies, materials, or services for personal or non-work-related purposes, you must obtain approval from the People Operations Team. 

Travel and Entertainment 

Travel and entertainment expenses must be consistent with your job responsibility and the Company’s needs and resources. You are expected to exercise reasonable judgment in the use of Company assets and to spend the organization’s assets carefully, mindfully, and conservatively. You must comply with internal policies relating to travel and entertainment expenses. 

Telecommunications Systems 

All Vault telecommunications systems, including electronic mail, internet access, facsimile, telephone service, or voicemail are the property of the Company and are to be used primarily for business and patient care-related purposes. Limited, reasonable personal use of the Company’s communications systems is permitted. You should assume that communications sent or received using work equipment are not private. Confidential or proprietary information must not be sent by any method for which security and confidentiality cannot be ensured. Personnel have no privacy rights in electronic and digital communications transmitted through or stored on the Company’s electronic communication systems. 

Subject to any applicable laws and internal policies and procedures, the Company reserves the right to periodically access, monitor, and disclose the contents of its communications systems. You may not use the Company’s communications systems or access to the internet at work to post, store, transmit, download, or distribute any threatening, knowingly reckless or maliciously false, or obscene materials. Additionally, the Company’s communications systems may not be used to send chain letters, personal broadcast messages or copyrighted materials that are not authorized for reproduction. 

Last Reviewed: January 2022.

Key Contact Information

Vault's Reporting Hotline

Contact information: 844-965-3497

Vaulthealth.ethicspoint.com

Vault’s Compliance Office

Email: [email protected]

Vault’s People Operations Team

Email: [email protected]

Vault’s Legal Team

Email: [email protected]

Vault’s Chief Compliance Officer

Katherine Kelton

Email: [email protected]

Vault’s Chief People Officer

Ron Massey

Email: [email protected]

Vault’s General Counsel

Hank Greenberg

Email: [email protected]