Compliance and ethics

Code of conduct

Every employee and director certifies each year that they have read and will follow our code of conduct, which covers conflicts of interest, gifts and hospitality, fair dealing, confidentiality and the use of company information. The code is administered by the General Counsel and overseen by the audit and risk committee.

Healthcare fraud and abuse laws

Equipment finance for hospitals touches the federal anti-kickback statute, the physician self-referral law and their state equivalents. Our vendor programs, referral arrangements and remarketing agreements are structured on fair-market-value terms, reviewed by counsel, and documented in writing. We pay nothing to any person for referring a hospital, and we do not finance equipment for physicians’ personal use.

Sanctions and anti-money laundering

We screen every client, manufacturer and funder against government sanctions lists at onboarding and daily thereafter, and verify the identity and ownership of every client before funding.

Privacy and patient data

Our systems are designed not to receive patient information. Where a hospital asks us to perform a service that would involve protected health information, we sign a business associate agreement first. Our privacy policy and statement on patient data explain more.

Information security

Our security program follows a recognized control framework and is audited each year by an independent firm. The latest service organization controls report is available to clients and funders under a confidentiality agreement.

Raising a concern

Employees, clients and suppliers can raise a concern about our conduct, in confidence and without retaliation, by writing to compliance@wardmorehealth.com, which is read by the General Counsel and the chair of the audit and risk committee. Employees can also report anonymously through the ethics line described in the employee handbook.