Last updated September 2025
Overview
IMO Health adheres to the highest legal and ethical standards. We conduct our business with strict observance of both the letter and spirit of the law, and the integrity of those individuals and entities that work for and on behalf of IMO Health is of utmost importance.
IMO Health, and those individuals and entities who work for and on behalf of IMO Health, are required to follow these principles through actions and behaviors.
- Provide a safe, inclusive and productive workplace.
- Create and maintain trust with our partners.
- Protect our resources.
- Seek guidance and answers.
- See something, say something.
IMO Health’s Code of Conduct may not address every situation; however, each principle of the Code of Conduct is supplemented by laws, regulations, IMO Health Policies, role descriptions and other official IMO Health documentation that provide more detailed guidance.
Who must follow our code?
This code applies to all IMO Health workforce members, including employees, contractors, consultants, temporary and other workers. This policy is also applicable to vendors or third-party service providers.
Principals of conduct
Provide a Safe, Inclusive and Productive Workplace. Everyone should feel safe while working up to their licenses. We are all responsible for providing and contributing to a safe, inclusive, and productive workplace. IMO Health and its Covered Persons are required to support this principle by acting in ways that promote the following characteristics.
- Celebrate diversity. Provide equal employment opportunities to all qualified applicants. We do not discriminate based on race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, genetic information, political affiliation, mental or physical disability, medical condition, sexual orientation, or any other characteristic protected by federal, state, or local laws.
- Treat one another with respect and dignity. We are all entitled to work in an environment free from discrimination, harassment and bullying in any form – verbal, physical or electronic.
- Resolve conflict peacefully. We are committed to a violence-free work environment, and we will not tolerate any level of violence or the threat of violence in the workplace. Under no circumstances should anyone bring a weapon of any kind to work.
- Do not work under the influence of drugs or alcohol. We do not work under the influence of or impaired by alcohol, illegal drugs (as classified under federal, state, or local laws) or controlled substances while conducting company business. We do not use or possess illegal drugs on IMO Health property or while engaged in any job-related activity.
- Do not pressure others to act contrary to laws, regulations and IMO Health policies. We do not pressure anyone to act or behave in a way that is contrary to state and federal laws or regulations, IMO Health’s Code of Conduct or other IMO Health Policies.
- Own your work. We take ownership in the work that we do and take accountably for our behavior and actions.
- Do not solicit or distribute non-work-related materials while working. We do not engage in non-work-related activities while at work. We do not ask others to donate to, participate in or engage in activities while working, unless approved by IMO Health’s People and Culture Department. We do not permit non-workforce members to solicit or distribute materials for non-work-related activities.
- Do not engage in activities that cause conflicts of interest. Activities that constitute a conflict of interest are prohibited. Covered Persons are required to disclose real or perceived conflicts of interest to IMO Health and may be asked to provide additional information regarding the relationship.
- Comply with laws and IMO Health policies. We comply with all laws, regulations and IMO Health policies that relate to and are relevant to our role, responsibilities, and position with IMO Health.
Create and Maintain Trust with our Partners. The continued success of IMO Health is dependent upon our customers’ and stakeholders’ trust, and we are dedicated to preserving that trust. Covered Persons owe a duty to IMO Health, its customers, and its equity holders to act in a way that will merit the continued trust and confidence of all our stakeholders. Covered Persons are required to support this principle by acting in ways that support the following guidelines.
- Play by the rules. We follow the laws, rules, and regulations of the United States and of all the places where we do business, including local privacy and data protection laws. We are accurate and truthful in representing business transactions to government agencies.
- Do not bribe or participate in corruption. U.S. and international laws prohibit bribery in virtually every kind of commercial setting. We do not bribe or accept a bribe. Ever. We use partners that have a reputation for integrity and report instances of unethical behavior or bribery.
- Compete fairly. Many countries have laws prohibiting competitors from joining forces to reduce competition in the marketplace. These laws are designed to promote free and fair competition. As such, we avoid any formal or informal agreements with competitors that limit competition.
- Use good judgment when giving and receiving gifts. When we offer or accept gifts, hospitality, or travel, we make sure they are appropriate and have a legitimate business purpose. We do not solicit gifts, hospitality, or travel from third parties or put third parties in a position where they feel obligated to provide something to do business with us. See IMO Health’s Travel and Expense Policy.
- Act in the best interest of IMO Health and its customers. If you are in a situation in which you may pursue a personal benefit for you, your friends, or your family at the expense of IMO Health or its customers, you may be faced with a conflict of interest. A conflict of interest can occur if your outside interests (financial, personal, or otherwise) interfere with IMO Health’s interests or your work-related duties. Avoid conflicts of interest and circumstances that reasonably present the appearance of it.
- Protect our customers’ information. Covered Persons may be exposed to confidential customer information such as contracts, financial information, personally identifiable information (PII) and protected health information (PHI) (including demographic and medical information of customers and employees). In addition to IMO Health policies, both federal and state law provide strict penalties for both companies and individuals that misuse such information. We do not:
- access or look at any customer information that is not required to do our job.
- discuss such information with anyone who does not have a need to know such information as part of that individual’s job.
- allow such information to be in a place where it may be exposed to unauthorized persons (left in a printer tray or on a desk); this includes email, databases, applications and third-party cloud services that have not been approved by the IMO Health Security Officer.
- • make available patient data and personal information in any form digital or physical within IMO Health or external to, except to authorized persons and in accordance with IMO Health’s Data Privacy and Security Policies.
Protect our Resources. We safeguard our resources, which include not only IMO Health resources, such as intellectual property and confidential information, but also our third-party’s confidential information and intellectual property. When you fail to protect our and our third-party resources, you and IMO Health may be exposed and liable to criminal and civil fines and penalties. Covered Persons are required to support this principle by acting in the following ways.
- Think before disclosing. We follow IMO Health policies and use best practices to protect access to confidential information of IMO Health, employees, and customers. You cannot undo an unauthorized disclosure. Information flows freely and often, so it is best to carefully consider before you make any disclosures of confidential information.
- Respect intellectual property rights. We preserve IMO Health’s intellectual property rights through copyrights, trademarks, patents, and other forms of intellectual property protection, and we respect the confidentiality and intellectual property rights of others. We do not:
- provide third parties with access to IMO Health intellectual property without authorization.
- use or provide third party intellectual property without authorization.
- use or copy third-party copyrighted materials, such as software, graphics, videos, and music, without a license or permission.
- Take care of our stuff. We expect everyone to be responsible and not wasteful with the IMO Health equipment and resources. Company funds, equipment and other physical assets are not to be requisitioned for personal use. The IMO Health Network (which includes both our network and the associated hardware) is a critical part of IMO Health’s property, both physical and intellectual. We follow all security policies. If you have any reason to believe that our network security has been violated promptly report the incident to us.
- Do not agree to terms and conditions or sign agreements for IMO Health where we do not have authority. We agree to terms and conditions or sign agreements, including shrink wrap or clickthrough, only when authorized.
Seek Guidance and Answers. No one knows everything. When we don’t know the answer, we don’t guess. We seek out guidance and answers by reviewing IMO Health’s Policies and processes and reaching out to internal resources like managers, departments, and subject matter experts.
See Something, Say Something. When you see or become aware of something that does not support IMO Health’s code of conduct, policies, laws, or regulations, report it.
IMO Health provides many avenues for reporting. We encourage you to:
- Speak with a supervisor or any member of management.
- Report to the People & Culture Department.
- Report to the Legal & Compliance Department.
- Submit a report to www.lighthouse-services.com/imohealth.
- Contact IMO’s Compliance hotline at 1-800-297-9630 (this is a third-party service staffed 24/7 365 days a year).
Both the online reports and telephone hotline options can be completed anonymously. All complaints and reports will be addressed.
Do Not Retaliate. When someone speaks up, we do not retaliate. IMO Health does not permit adverse actions or consequences when a Covered Persons refuses to do something that violates this Code of Conduct, IMO Health policies or the law, raises a concern in good faith about potential violations or misconduct; or cooperates with an investigation. Please reference our Non-Retaliation Policy.
Compliance
IMO Health workforce members must adhere to this Code of Conduct policy, as well as all other policies and procedures set by IMO Health. Failure to comply with this and any other IMO Health policy or procedure may result in disciplinary action, up to and including termination of employment.
Conclusion
We all know that “Do the right thing” is easier said than done. Not every dilemma you encounter will appear here or elsewhere in IMO Health’s policies and procedures, but it is our hope that you have been provided the tools and resources to make the best decisions you can for the IMO Health community and to comply with both the letter and spirit of this Code. If you have a tough decision to make, take your time and do not do it alone. Call the hotline, talk to your manager, talk to People & Culture, or talk to the Legal & Compliance Department.
