Intelligent Medical Object's Code of Conduct

Last updated April 2021


Intelligent Medical Objects (IMO) 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 is of utmost importance.

IMO, and those individuals and entities who work for and on behalf of IMO, are required to follow these principals through actions and behaviors.

  1. Provide a safe, inclusive and productive workplace.
  2. Create and maintain trust with our partners.
  3. Protect our resources.
  4. Seek guidance and answers.
  5. See something, say something.

IMO’s Code of Conduct may not address every situation; however, each principal of the Code of Conduct is supplemented by laws, regulations, IMO Policies, role descriptions and other official IMO documentation that provide more detailed guidance. Covered Persons, as defined below, are expected to have a working familiarity with applicable IMO Policies and documents.

Who must follow our code?

Covered Persons include all IMO employees, officers, directors, contractors, consultants, temporary and other workers, and applicable vendors and third-party service providers, whether individual or entity. Covered Persons must follow this Code of Conduct while performing services for or representing IMO.

All Covered Persons are expected to conduct themselves with the pride and respect associated with their positions, their fellow employees, third-parties and IMO. Care should always be taken to use good judgment and discretion in carrying out IMO business. The highest standard of ethical conduct should always be used.

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 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 property or while engaged in any job-related activity.
  • Do not pressure others to act contrary to laws, regulations and IMO policies. We do not pressure anyone to act or behave in a way that is contrary to state and federal laws or regulations, IMO’s Code of Conduct or other IMO 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’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 and may be asked to provide additional information regarding the relationship.
  • Comply with laws and IMO policies. We comply with all laws, regulations and IMO policies that relate to and are relevant to our role, responsibilities and position with IMO.

Create and Maintain Trust with our Partners. The continued success of IMO is dependent upon our customers’ and stakeholders’ trust, and we are dedicated to preserving that trust. Covered Persons owe a duty to IMO, 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 principal 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. 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 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 in order to do business with us.
  • Act in the best interest of IMO 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 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’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 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 Security Officer; or
    • make available patient data and personal information in any form digital or physical within IMO or external to, except to authorized persons and in accordance with IMO’s Data Privacy and Security Policies.

Protect our Resources. We safeguard our resources, which include not only IMO 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 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 policies and use best practices to protect access to confidential information of IMO, 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’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 intellectual property without authorization;
    • use or provide third party intellectual property without authorization; or
    • 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 equipment and resources. Company funds, equipment and other physical assets are not to be requisitioned for personal use. The IMO Network (which includes both our network and the associated hardware) is a critical part of IMO’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 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 see out guidance and answers by reviewing IMO’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’s code of conduct, policies, laws or regulations, report it.

IMO 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
  • 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 does not permit adverse actions or consequences when a Covered Persons refuses to do something that violates this Code of Conduct, IMO 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.


Covered Persons are required to comply with this Code of Conduct and all other policies and procedures applicable to them and established by IMO from time to time. A Covered Person’s failure to follow or comply with federal, state and local laws and regulations, IMO’s Code of Conduct or other policies, procedures, IMO documents applicable to them may result in action or consequences by federal, state and local entities as well as IMO. Such actions and consequences may include, but are not limited to, disciplinary action, termination, fines and/or penalties.


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’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 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 don’t do it alone. Call the hotline, talk to your manager, talk to People & Culture or talk to the Legal & Compliance Department.