LETTER FROM THE PRESIDENT

For more than 90 years, The Evangelical Lutheran Good Samaritan Society has sought to serve older persons and others with Christ-like dignity and compassion. We believe that our Christ-centered mission calls us to the highest possible standards of excellence in our work. We want to provide excellent care and demonstrate excellence in addressing the ethical decisions we face on a daily basis.

As we strive to fulfill our mission, we are ever mindful that the government, through its Medicare and Medicaid programs, is the Good Samaritan Society’s single largest payment source. Under Medicare and Medicaid, the government pays millions of dollars to thousands of healthcare providers each year. The government relies on laws, regulations and other forms of written guidance to communicate its requirements of healthcare providers that receive payments for services rendered. The Society’s ongoing ministry depends on consistently meeting government requirements.

Our Compliance Program describes the system we have in place to help us address governmental regulations. The Program is organized around the same seven elements suggested by the government. In addition, we have built it upon existing Society programs such as the Job Description/Performance Feedback System and QAPI (Quality Assurance Performance Improvement).

As an employee of the Society, you play a vital role in ensuring the success of our Compliance Program. Therefore, it is essential that you read and understand the information in this handbook so that you will know how to obtain further information and report potential violations.

Thank you for your work you do each day to carry out the Society’s mission and for your careful attention to the Compliance Program set forth in this handbook.

Sincerely,

David J. HorazdovskyPresident and Chief Executive Officer

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TABLE OF CONTENTS

LETTER FROM THE PRESIDENT..........................................1TABLE OF CONTENTS...........................................................2COMPLIANCE PROGRAM ELEMENTS

I. STATEMENT OF PRINCIPLES AND STANDARDS OF CONDUCT......................................3

II. CORPORATE COMPLIANCE OFFICER.....................4III. ORIENTATION AND CONTINUING EDUCATION......5IV. REPORTING COMPLIANCE CONCERNS..................6V. MONITORING OUR COMPLIANCE EFFORTS...........7VI. EMPLOYEE SCREENING AND DISCIPLINARY

MEASURES..................................................................8VII. INVESTIGATION AND CORRECTION

OF PROBLEMS............................................................8CONCLUSION..........................................................................9INTRODUCTION TO CODE OF ETHICS...............................10CODE OF ETHICS.................................................................12ACKNOWLEDGMENT...........................................................26

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I. STATEMENT OF PRINCIPLES AND STANDARDS OF CONDUCT

A. Statement of PrinciplesThe Evangelical Lutheran Good Samaritan Society’s (the Society) “Code of Ethics” (which is included at the end of this handbook and in the Employee Handbook) expresses our general expectations of all Society employees with respect to ethical conduct. It is central to fulfilling our mission and sets the tone for our Compliance Program. Please read the Code carefully, and ask questions of your supervisor or location management if any of its principles are unclear to you.

B. Standards of ConductPolicies and procedures that reinforce the Society’s high standards of care and financial accountability are part of the fabric of our organization and serve as standards of conduct expected from all employees. Many of our policies and procedures address areas with which the government, too, is concerned.

A Society resource entitled “Compliance Program Guidelines” provides a list (called a “roadmap”) of the government’s most recently emphasized expectations for nursing facilities and home health agencies, and the Society’s corresponding policies and procedures. As new compliance standards are developed by the government – or by the Society – as a result of our internal quality improvement activities, our policies and procedures will be modified, and the “roadmap” updated accordingly.

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Our Employee Handbook and Job Description and Performance Feedback System include many of the same compliance-related standards of conduct as are listed in the roadmap. Supervisors and location management are expected to be familiar with the policies and procedures that apply to their area(s) of responsibility and review them with any employees or contractors whose work they supervise, ensuring the policies and procedures are understood and followed.

Each employee is responsible for knowing, understanding and following the policies and procedures that apply to his or her position. If you believe your training in this regard is incomplete, let your supervisor or location management know – or call the corporate compliance officer. (See Section IV for information about how the corporate compliance officer can be contacted.)

II. CORPORATE COMPLIANCE OFFICER

Our corporate compliance officer (CCO), a National Campus employee, provides Society-wide leadership for our compliance efforts. The CCO’s responsibilities include helping the Society to stay abreast of government requirements in the area of compliance, and coordinating internal activities geared toward improving our compliance. Location management is responsible for compliance activities at the local level.

The CCO should be viewed as a resource to any employee who seeks further information about government requirements or has concerns about whether the Society is meeting its compliance obligations.

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III. ORIENTATION AND CONTINUING EDUCATION

A. Employee OrientationEach employee receives an overview of our Compliance Program through the Society’s General Orientation program. More specific job expectations related to compliance are listed in each employee’s Competency Verification/Training Checklist (CVTC).

B. Continuing EducationContinuing Education in compliance occurs on an individual basis as well as on a group basis.

On an individual basis, each employee and his/her supervisor is expected to review the employee’s compliance-related job responsibilities in the course of the employee’s annual performance review.

On a group basis, each employee is offered continuing education, on topics including compliance, through various Society programs and publications. It is important that all employees take advantage of such opportunities.

C. AccountabilityEach employee is responsible for knowing and understanding the policies and procedures concerning his or her position – including those that relate to compliance.

Supervisors and location management are responsible for providing each employee with both general orientation and orientation specific to the employee’s job responsibilities. Supervisors and location management also are expected to review annually the performance of each employee reporting to them. Both the orientation process and the annual performance review process serve as important opportunities to review the Society’s compliance-related expectations of employees.

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IV. REPORTING COMPLIANCE CONCERNS

The Society strives to promote a mutually supportive atmosphere among all of its employees. It is our goal that employees feel comfortable discussing compliance-related concerns with their supervisor or location management so that problems may be solved at the local level. However, any Society employee (or contractor) may report such concerns directly to the corporate compliance officer if, for whatever reason, they are not comfortable raising the issue with their supervisor or administrator.

The important thing to remember is that you must report any compliance concern you have. It is the “right thing to do,” and it is also a requirement of your continued employment by the Society.

The corporate compliance officer may be reached by telephone or in writing:1

Telephone: Compliance Solutions Line:(800) 631-6142

By Mail: Corporate Compliance Officer4800 West 57th StreetP.O. Box 5038Sioux Falls, SD 57117-5038

Compliance representatives are available Monday through Friday from 7 a.m. to 7 p.m., Central Time. You may leave a voice message if compliance representatives are not available to take your call, or you may call back.

1 If your concern involves Cedar Lake Village, please write to: Cedar Lake Village Corporate Compliance Officer, c/o Corporate Secretary, 4800 West 57th Street, P.O. Box 5038, Sioux Falls, SD 57117-5038.

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There is no obligation to identify yourself when you call, as long as the Society is able to investigate the concern and take necessary corrective action without knowing your name. The Society will not retaliate against an employee for making a good faith report.

If you are in doubt about an issue or have a concern, ask! Keep asking until you get an answer that makes sense. If you know it is wrong, don’t do it.

Consider these questions: Is it consistent with Society policies and procedures? Is it consistent with Society values and principles? How would you feel if you did it? How would it look to family, friends, residents/clients

or others in your community? How would you feel if it were reported on the front

page of your hometown newspaper?

V. MONITORING OUR COMPLIANCE EFFORTS

We monitor our compliance efforts in the following ways:

A. Monitoring by Individual LocationsEach location monitors how well it is meeting government requirements by using our Quality Assurance Performance Improvement (QAPI) process. That process is conducted by each location’s QAPI Committee. From time to time, we focus on a particular compliance area by adding one or more performance indicators to that process.

Reports of compliance concerns by employees also serve as an important means of monitoring how we are doing in meeting our compliance obligations.

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B. Society-Wide MonitoringSociety-wide monitoring of our compliance performance is coordinated by the corporate compliance officer – through periodic, corporate-level audits of particular compliance areas. Such audits involve National Campus functions, Society-wide problems identified through the survey readiness process, QAPI, issues reported by employees and government enforcement priorities.

VI. EMPLOYEE SCREENING AND DISCIPLINARY MEASURES

A. Employee ScreeningEach employment candidate must produce evidence of his or her licensure (or certification) for any position that requires it. The Society also performs a background check on each employment candidate. (Background checks include both criminal convictions and offenses related to the Medicare or Medicaid programs.)

B. Disciplinary MeasuresViolations of the Society’s policies or procedures regarding compliance with laws and regulations (including a disregard of one’s duty to report violations, or a supervisor’s or location management’s failure to properly train new employees) are of a serious nature. Disciplinary measures associated with such violations are noted in the Society’s Employee Handbook. Certain violations may result in immediate termination of your employment.

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VII. INVESTIGATION AND CORRECTION OF PROBLEMS

When a compliance concern is raised, an investigation will be conducted and a determination made as to the most appropriate means of correcting any problem that is identified.

Isolated incidents generally will be addressed by requiring additional training of the employee (or employees) involved, although some circumstances may warrant disciplinary action.

System-wide problems generally will be addressed in QAPI policies and procedures. At the local level, this will involve the QAPI Committee. Within our National Campus, a committee of management employees meets to evaluate compliance risks and assigns resources to address them.

Compliance problems that require more confidential handling will be addressed by the Corporate Compliance Officer, who may enlist the cooperation of others.

CONCLUSION

The Society’s well-being depends on our ability to consistently meet government requirements. It is up to you to become familiar with the government requirements that apply to your position and follow the corresponding policies and procedures. Your failure to meet those requirements – and to help the Society as a whole to meet them – carries serious consequences.

This handbook is only a summary of the Good Samaritan Society’s Compliance Program. Please see the Compliance Program Guidelines or your supervisor or location management for further information.

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INTRODUCTION TO CODE OF ETHICS

The mission of The Evangelical Lutheran Good Samaritan Society is to share God’s love in word and deed by providing shelter and supportive services to older persons and others in need believing that “In Christ’s Love, Everyone Is Someone.”

As we think about the ways we live and work here in the Society, “In Christ’s Love” is the best place to begin. God’s love for each of us - shown most clearly in the gift of His Son, Jesus Christ - provides the foundation for all we do and say. Our mission calls each of us to follow in the path of Christ and emulate eight traits that Jesus exhibited in His life: compassion, honesty, perseverance, joy, humility, acceptance, courage and love. This way of life within our organization is The Good Samaritan Society Way.

Why should we try to be honest and kind and loving with each other? Because God has been honest and kind and loving with us. God’s great love assures us that we are special people. But it also reminds us that all the residents and clients we work for and all the employees we work with are special, too. God’s love creates a Christian community in which each of us has both rights and obligations.

Some of the rights we have, include, the right to be treated with respect, the right to be dealt with openly and honestly, the right to expect fair and just relationships between all members of the community, the right to have a voice in community life and the right to be fully accountable for the work we do. The obligations we have mirror these rights. We are obligated to treat others respectfully, openly, honestly and so on.

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No community, Christian or otherwise, always lives up to all these rights and obligations. But they are ideals we continue to strive for and work toward. This Code of Ethics, like a map, is intended to give us directions toward these ideals. By taking this code seriously, we each do our part to strengthen our commitment to The Good Samaritan Society Way, no matter the setting or service model, and help make the Society a place where God’s love is understood, experienced and shared. When that happens, our mission statement becomes more than words. Our actions give it the power to change people’s lives as they see and feel God’s love at work in and through us. We know what a difference your words and actions can make and just how important you are to everyone who lives and works in your Good Samaritan Society community.

Please read, think through and accept this Code of Ethics with the understanding that it is much more than a formality. Our Code of Ethics is affirmed and represented in Society policy and standards to which we must all be held accountable.

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CODE OF ETHICS(With Expository)

1. I will do my part to furnish high-quality Christian care and services that are appropriate to each resident’s and client’s total well-being, to include physical, spiritual, mental, emotional, social and vocational needs.In a basic sense, doing our part to furnish high-quality care and services means to responsibly recognize and respond to our residents’ and clients’ needs while demonstrating that they are loved and worthy of the same care and treatment we ourselves would like to receive.

It occurs in everyday work assignments such as following care plans; thoroughly cleaning rooms and other spaces; informing the nurse of changes in a resident’s or client’s condition; encouraging meaningful activities; providing nutritious meals; providing opportunities for physical fitness; accurately assessing needs; completing paperwork; developing caring relationships and nourishing faith through prayer and participation in worship.

Well-being is actively pursuing a balanced life. It is the process by which people work toward being the best that they can be within their own personal limitations, leading to meaning, value and purpose. It models Christ’s invitation to love God with heart, soul, mind and strength and reinforces the commandment to love our neighbors as ourselves. We are social beings who want to build strong relationships within our families and in the community and find satisfaction in our work, service and leisure time.

Providing appropriate care also means ensuring careful stewardship of scarce financial resources based on medical necessity.

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Residents and clients frequently request additional services, such as transportation or housekeeping. Services such as these will be provided or coordinated within the means appropriate to the Good Samaritan Society community.

2. I will protect our residents and clients from abuse and neglect in any form and promptly report any concerns I have that such abuse or neglect may be occurring.Protecting our residents and clients from harm is among our most basic duties. Abuse takes the forms of verbal, physical, mental, sexual, involuntary seclusion, neglect and/or misappropriation of resident and client property. We do not tolerate abuse. Our goal is to serve each resident and client with the compassion and dignity modeled by Jesus Christ, and we seek to do this by providing the highest quality of care and services for each person within an affirming environment.

The potential for abuse exists in an environment where employees work in sometimes stressful situations and vulnerable individuals sometimes can be frustrated with their personal circumstances. We must foster a culture of reporting and accountability rather than a culture of tolerance. This means that everyone feels comfortable bringing issues forward; issues are immediately addressed; complete and thorough investigations are done; appropriate follow-up takes place and allegations are reported to internal and external entities as appropriate.

Residents and clients have special possessions and expect that they will be safe and well cared for by employees. Safeguarding our residents’ and clients’ belongings includes telling what you know or suspect about missing items and/or misappropriated funds or property.

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We need to know and follow the Society’s policy and procedures regarding preventing, reporting and investigating all forms of abuse. This includes awareness of and compliance with the seven key components of abuse and neglect. The seven key components are listed below, along with examples of how the Society addresses these important areas.

Screening, such as criminal background checks Training, such as orientation and annual in-services Prevention, such as audits and grievance

procedures Identification, such as indicators that assist

employees with identifying abuse or neglect Investigation, such as procedures for conducting an

effective investigation Protection, such as procedures for ensuring that

residents and clients are protected from harm during an investigation

Reporting and response, such as processes to report incidents and establishing plans to improve quality

3. I will be respectful of our residents’, clients’, family members’ and co-workers’ diverse experiences and will support and encourage the unique point of view each individual brings to care planning and delivery of services.Our motto, “In Christ’s Love, Everyone Is Someone,” is lived out in the respectful and encouraging way we treat one another. With Christ as our model, we involve care-giving employees, residents and clients, family members and others as appropriate in care planning and delivery of services as an effective means of accomplishing our aim — treating everyone, including those with beliefs and cultural traditions different from our own, as valued, respected and loved.

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4. I will be respectful of my co-workers as it relates to 1) my behavior toward them and 2) their diverse experiences and education; and strive to promote a supportive work environment.It is important to strive for an environment where all employees experience acceptance and love and feel valued for who they are, not simply for the work they do. This comes out of the belief that we love and forgive others because of the unconditional love that God first gave us through His son, Jesus Christ.

Respect means treating your co-workers as professionals and showing courtesy and consideration for the full range of their talents and gifts. Together, we can celebrate the contribution that our combined gifts make to the Society’s mission.

In a supportive environment, we know that in one way or another that we, as humans, all have needs. A supportive environment fosters and encourages honesty, forgiveness, prayer, personal growth, teamwork, open communications, mutual respect, conflict resolution and a commitment to the Society’s mission. No matter the situation, prayer is available and offered and employees take time to help each other in times of personal need.

Our Good Samaritan Society communities are increasingly diverse places. Regardless of your particular perspective, your regard for those you work with must reflect a respect for human beings who are created in the image of God, and thus worthy of love and respect. Our motto, “In Christ’s Love, Everyone Is Someone,” challenges each of us to recognize the unconditional love of God in Christ for every one of us. While we recognize that there may be many things about which we will disagree, there always will be one thing upon which can agree: we all need to love and be loved.

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5. I will honor the confidentiality of all information regarding our residents, clients and co-workers.Even the smallest details about our residents’ and clients’ care could be information they don’t want others to know. When you work in healthcare, it is easy to take confidential information for granted, whether it is protected health information (PHI) or confidential employee information. Awareness of your behavior and the potential for accidental disclosure must remain a primary consideration. An example of this is the grocery store. Consider that others may overhear conversations and carefully choose the place and manner in which you have them.

When sharing PHI among co-workers, only share the minimum amount necessary to carry out your job duties. Keep “minimum necessary” in mind so that sharing information does not turn into gossip.

While it is not our intent to restrict employees from discussing terms and conditions of their employment, we all need to be mindful that medical records and employee files contain confidential information that should be maintained with privacy and security standards in mind. Technology, such as computers, handheld devices, phones and other communication devices, provides numerous ways to conduct and document our work and must be used in ways that ensure confidentiality and privacy of PHI and employee information.

6. I will maintain the necessary qualifications for my position, striving to improve my knowledge and skills through continuing education and training.As residents and clients continue to come to us with more difficult and numerous needs, it is vitally important to continue to improve our knowledge and skills, be it through work-sponsored training or formal degree-granting programs. It is part of our commitment to our residents and clients.

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People whose positions require licensing and/or certification must comply with the educational and other legal requirements to keep their licensure and/or certification in force.

The healthcare environment is always changing, and it is important to consider all information available to help you in your work. Information may come from many sources, such as the Web Portal, web-based training, in-services, outside workshops, self-study courses and meetings. It is vitally important that you take personal accountability for accessing information when needed so that you can provide high-quality care to those you serve.

7. I will strive to understand and comply with all applicable laws and regulations governing my action and conduct in regard to my duties and responsibilities.Knowing and following the laws and regulations for your own job are not only the right things to do, but they also are necessary to avoid severe government penalties. Make it a point to attend and pay attention to educational opportunities and to know and follow the policies and procedures that apply to your job.

8. I acknowledge that among the Society’s highest priorities is the health and safety of the residents, clients and ourselves; accordingly, I will strive to do my job so that no harm is caused to myself, co-workers, residents, clients or the public.

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We all share a duty to participate in safety activities such as fire drills and safety audits. We also share a responsibility to report and correct any unsafe conditions, to learn how to safely operate equipment and to take the time necessary to perform our tasks safely. Examples of unsafe conditions might include water that runs too hot, malfunctioning equipment, wet floors without proper signage, handrails in disrepair or placement of equipment, furniture or other property that inhibits proper access and egress in the building.

9. I will do my part to make sure our residents and clients — and others making payment on our residents’ and clients’ behalf — are billed only for services for which there is complete and truthful documentation.I never will deliberately alter or falsify clinical, financial or employment records.

In order to bill and receive correct reimbursement for our services, we must ensure we have complete and accurate documentation that provides the level, amount and appropriateness of service received. Severe fines and penalties can result from billing for services that we can’t prove with good documentation or from poor maintenance of employment records.

It never is acceptable to knowingly falsify clinical, financial or employment records for any reason. All information qualifies as business information, no matter the form or format that it is created or used for Society purposes. Always put the correct dates on records and never sign or date another person’s signature. Always perform your duties with the appropriate security access you have been given and safeguard your passwords. Always perform your duties within your scope of practice.

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10. I will not knowingly and willfully ignore errors or problems or misrepresent facts. I will immediately attempt to resolve issues, and if I cannot, I will bring them to the attention of a supervisor. It is important to promote a culture where everyone feels comfortable asking questions, discussing problems and working together for problem resolution. Errors or problems left unfixed only get worse. It is important to follow the chain of command in your position when raising a concern or seeking direction regarding compliance issues. In most situations, the supervisor should be able to address the concern. If this is not addressed appropriately, however, this process then allows for matters of concern to be elevated to management including the location’s management, human resources (HR) department, National Campus Human Resources and possibly the corporate compliance officer. The following process should be used to report suspected violations of Society policy and procedures, federal and state laws, rules and regulations as well as any violations under the Society’s Code of Ethics.

a. As an employee, you should openly discuss your concern with your supervisor. The supervisor should be knowledgeable about the appropriate laws, regulations, etc., and should be able to handle most, if not all, situations.

b. If you are not comfortable in talking with your supervisor (because the issue may involve your immediate supervisor), then you should proceed in discussing this with your supervisor’s supervisor or seek HR assistance for next steps.

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c. If an employee feels the matter cannot be handled by the supervisor or the supervisor’s supervisor, you must contact the Society’s corporate compliance officer in one of the following two ways:

Telephone: Corporate Compliance Hotline(800) 631-6142

By Mail: Corporate Compliance Officer4800 W. 57th St.P.O. Box 5038Sioux Falls, SD 57117-5038

Only concerns or issues that cannot be resolved locally should be submitted to the Corporate Compliance Hotline, unless circumstances dictate otherwise.

Non-retaliation: The Society strictly prohibits any kind of retaliation when someone raises a good faith concern, seeks supervisor or supervisor’s supervisor response or calls the Society’s Corporate Compliance Hotline with a possible ethics or compliance violation. Should retaliation occur, this will result in corrective action up to, and including, termination of employment.

11. I will promote high-quality, diversified services for all persons in our communities.All people are of great value and deserve dignified treatment. Because we believe “In Christ’s Love, Everyone Is Someone,” our services are available to anyone whose needs can be met by our employees and resources and will be provided to qualified individuals of all faiths and beliefs without regard to race, religion, color, national origin, gender (including pregnancy, gender identity, gender expression and sexual orientation), genetic information, age, marital or familial status, disability, veteran status or other protected status.

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We will be sensitive to the needs of our communities and, to the extent that is possible, strive to partner with them in providing an array of services to meet those needs.

12. I will exercise good stewardship in all purchasing and referral decisions and base them on principles of cost-effectiveness and value-added benefits. It is important to avoid even the appearance that we are engaging in an activity, be it a purchase or referral decision, with any self-serving motivation. It always is best to check first with your supervisor, the location’s management or the Society corporate compliance officer before conducting any Society business where you or a family member have or could have a personal interest.

It is explicitly against the law to accept compensation of any kind, direct or indirect, in cash or in kind (e.g., trips, prizes, gift certificates, etc.) in exchange for referring or influencing the referral of residents to or from Society locations.

It also is against the law to accept or offer compensation of any kind to make or influence the decision to purchase products or services to be used in the care of our residents and clients when at least some part of the money used to make these purchases comes from government healthcare programs.

Charitable gifts to the location or the Society as a whole usually are acceptable. Gifts to individuals are allowable within the guidelines set forth in Society policies only when the value of the gifts are so small that it is unlikely the giving or receiving of them would influence a referral or purchasing decision.

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13. I will perform my duties in a way that promotes the public’s trust in The Evangelical Lutheran Good Samaritan Society.

I understand that my off-duty conduct may potentially affect the public’s trust in my work performance for The Evangelical Lutheran Good Samaritan Society.Our mission statement gives each of us a basic duty to ourselves and others to be truthful in everything we say or write, including, but not limited to, our clinical documentation, investigations, location records, expense reporting and dealings with and/or for whom we work. Our good name and reputation is something we each value as individuals, as does the Society as an organization. Our good name and reputation is ours to keep or to lose and it is much easier to lose than to win back. Whether we are on or off duty, our conduct can influence the public’s trust both in the individual and the Society as a whole.

Legal off-duty conduct can be thought of as lawful conduct off the employer’s premises during non-working hours that is not in direct conflict with the essential business-related interests of the employer. While the Society does not dictate legal off-duty conduct, it is important for Society personnel to understand that the public may observe our legal off-duty conduct and associate that conduct with the Society’s good name and reputation as well as with our own work performance as Society personnel.

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Additionally, for those in leadership positions, a Society leader often is the public representative of the mission of the Society in a given location. A Good Samaritan Society leader should refrain from conduct that may present the Society in a negative light that could lessen the leader’s ability to be the spiritual leader of that location, or that could harm the Society’s reputation and/or that location’s reputation. A Society leader also should refrain from engaging in conduct that may lessen his/her ability to meet performance expectations of the Society. If the legal off-duty conduct does have a negative effect on the ability of the Society leader to meet the performance expectations of the Society, the continuation of employment with the Society at that respective location or any location within the Society may be called into question. This also is the case should such conduct present the Society or the given location in a negative light.

The Society may address legal off-duty conduct on a case-by-case basis when it presents the Society in a negative light, or when it lessens the ability of the Society leader to be the spiritual leader, or when it could be deemed to harm the Society’s reputation and/or the given location’s reputation, or when it has a negative effect on job performance. Examples of legal off-duty conduct that may require intervention by the Society include, but are not limited to, habitual gambling; excessive public drinking or intoxication; inappropriate use of social media; lifestyle choices and the use of medicinal marijuana.

Examples of job-related off-duty misconduct that the Society may address include: driving under the influence of alcohol if your role at the Good Samaritan Society location is driving residents to and from appointments; action taken for assault and battery if your role involves contact with residents and clients; action taken for theft or fraud if your role provides you access to resident, client or Society property and information; or substantiated threats made to residents, clients, employees or families outside of work.

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14. I will encourage and support volunteerism as it benefits both those who are served and those who serve. Volunteers provide many services to our residents and clients that would not otherwise be available. Thus, they provide a valuable service that we encourage. They come from both the communities we serve and from the employees. While the Society provides meaningful opportunities to connect with our community and be involved in the lives of others, the invitation is entirely voluntary. Participating in community events and organizations also are ways of sharing and experiencing the benefits of volunteerism.

15. I will apply ethical standards and be honest and forthright in any representations I make to residents, clients and people in the community.Honesty means being truthful, forthright, sincere and fair in our spoken and written conduct with others.

In conducting our work in a professional and truthful manner, we strive to reflect the eight traits of The Good Samaritan Society Way: compassion, joy, acceptance, love, honesty, perseverance, humility and courage. It is important that we consider ourselves in positions of trust and act accordingly. Applying ethical standards is difficult to describe. Some examples follow: Providing services within the boundaries of our

education, training, license, certification or other relevant professional experience

Taking responsibility and credit only for work performed and for which you have contributed

Honoring the privacy and confidentiality of those with whom we serve and work

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Avoiding actions that may demean a person based on gender, race, color, religion, national origin, age, disability, veteran status or other relevant aspect of diversity

Addressing concerns and conducting or participating in investigations in a fair and objective manner

Using resources in a proper manner Avoiding participation in or association with

dishonesty, fraud or deception Being alert to and avoiding conflicts of interest that

interfere with professional discretion and impartial judgment

Avoiding taking unfair advantage of residents, clients and others

Seeking clarification of your role in a situation if you are concerned that a conflict of interest may exist

Therefore, I dedicate my work in healthcare to offering service that will uphold the motto of the Good Samaritan Society: “In Christ’s Love, Everyone Is Someone.”

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Rev. 4/13

ACKNOWLEDGMENT

I acknowledge that I have received a copy of The Evangelical Lutheran Good Samaritan Society’s Compliance Program Handbook.

I understand that the information contained in the Society’s Compliance Program Handbook provides a general description of the corporate compliance program, and further information is available in the Society’s Compliance Program Guidelines and from the corporate compliance officer or my administrator.

I understand that I am responsible for knowing, understanding and following the policies and procedures that apply to my position.

I understand that failure to abide by the Code of Ethics and other standards of the Compliance Program may result in corrective action, up to and including termination.

Print Employee’s Name

Employee’s Signature

Date

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