Corporate Compliance Program

Purpose

The Board of Directors of Bethany Lutheran Homes, Inc. has directed the development of a Corporate Compliance Program to reaffirm the commitment of Bethany Lutheran Homes, Inc. to abide consistently to all legal and ethical standards applicable to the delivery of health care and socially-related services and the future operation of residential facilities for the elderly.

A Corporate Compliance Program is a systematic effort to prevent, detect, report, and resolve violations of the law throughout the organization. Corporate Compliance Programs are designed to ensure that the organization’s employees and agents conduct themselves in conformance with all applicable legal requirements.

However, consistent with the mission of Bethany Lutheran Homes, Inc., this program involves more than complying with government regulations. Employees of Bethany Lutheran Homes, Inc. should view corporate compliance as a part of their calling as individuals and professionals in the ministry of Lutheran health care.

To that end, Bethany Lutheran Homes, Inc. has developed a Corporate Compliance Program, which directly relates to employees and contractors involved with Bethany Lutheran Homes, Inc. These policies and procedures provide guidance to all employees and contractors regarding the operation of the Corporate Compliance Program and the available mechanisms through which corporate integrity issues can and should be reported.

Each employee and contractor of Bethany Lutheran Homes, Inc. is responsible for adhering to the policies and procedures of the Corporate Compliance Program.

Reporting Procedures

If a Bethany Lutheran Homes, Inc. employee or contractor has concerns regarding any ethics or corporate compliance issue, including any of the standards of conduct or policies and procedures described in the Bethany Lutheran Homes, Inc. Corporate Compliance Handbook:

  • That employee or contractor should immediately contact one of the following:
    • His or her supervisor
    • The Bethany Lutheran Homes, Inc. Corporate Compliance Officer (Patrick Senzig. Phone # 608-406-3923)
    • Human Resources
    • BLH Inc. Website – Corporate Compliance Tab
  • All reports regarding an ethics or corporate compliance issue are reviewed by the Corporate Compliance Officer (CCO) and investigated by the CCO or an appropriate Compliance Committee member.
  • The identity of an individual who submits a report, a witness who provides information regarding a report, and the target of the compliant will be kept confidential to the extent possible consistent with a thorough and impartial investigation. Retaliation is strictly prohibited against anyone who in good faith reports a corporate compliance issue.

Types of Issues to Report

All employees or contractors are expected to report any reasonably suspected or known violations of any of the following:

  • Applicable legal requirements
  • Bethany Lutheran Homes, Inc. standards of conduct, policies or procedures contained in the Corporate Compliance Handbook and any attachments.
  • Other corporate compliance policies and procedures that are currently included in the Bethany Lutheran Homes, Inc. policy and procedure manual, or which Bethany Lutheran Homes, Inc. may adopt in its ongoing operation.
  • Any employee or contractor:
    • who acquires information that gives him or her reason to believe that another employee or contractor is engaged in or plans to engage in conduct prohibited by the Corporate Compliance Handbook should promptly report such information to either their supervisor or the CCO
    • should also report to the Corporate Compliance Officer any information indicating that any other person or contractor employed with Bethany Lutheran Homes, Inc. plans to violate the standards of conduct or policies and procedures contained in the Corporate Compliance Handbook.
    • who is instructed, directed, or requested to engage in conduct prohibited by the Corporate Compliance Handbook should promptly report such information to either their supervisor or the CCO, Human Resources, or the Hotline.
  • Bethany Lutheran Homes, Inc. prohibits any supervisor or employee to retaliate against another employee or contractor for reporting corporate compliance issues in good faith. Should it be determined that retaliation has taken place, appropriate disciplinary action will take place up to and including termination.
  • Please do not report items that can be addressed with your supervisor such as; you don’t like the employee meals or that you are unsatisfied with your schedule, or items that should be addressed by human resources related to things such as hiring, wages, performance, employee relations, promotions, termination, etc.