Code of Ethics & Business Conduct
Statement of Our Core Values
SDL Brokerage & Group Health Solutions, V 1.0 – 2022
SDL Brokerage and Group Health Solutions will improve the health and well-being of individuals by producing, training, and supporting qualified agent representatives to inform and educate the public on healthcare plans and options that best serve their needs and desires.
- Smart work and education separate us from competition.
- Stay focused on the Mission and we will be successful to help and serve others.
- Customers want and deserve our industry leading trained advisors.
- Operate with the highest integrity.
- Be the top educated professionals in our field.
- Follow legal, moral, and ethical guidelines.
- Provide a top performing environment to work.
- Deliver industry leading service to our agents and clients.
Provide Academy/ Union/ Network of Personal Representatives/ Healthcare Agents who guide/ advocate/ navigate/ prepare/ promote healthcare insurance/ decisions/ health and wellness decisions to members/ people/ families who are making health impacting choices/ decisions at any stage of their life/ throughout life/continuum.
Build Trust and Credibility
The success of our business is dependent on the trust and confidence we earn from our employees, and customers. We gain credibility by adhering to our commitments, displaying honesty and integrity and reaching company goals solely through honorable conduct. It is easy to say what we must do, but the proof is in our actions. Ultimately, we will be judged on what we do.
When considering any action, it is wise to ask: will this build trust and credibility for SDL Brokerage and Group Health Solutions? Will it help create a working environment in which SDL Brokerage and Group Health Solutions can succeed over the long term? Is the commitment I am making one I can follow through with? The only way we will maximize trust and credibility is by answering “yes” to those questions and by working everyday to build our trust and credibility.
Respect for the Individual
We all deserve to work in an environment where we are treated with dignity and respect. SDL Brokerage and Group Health Solutions is committed to creating such an environment because it brings out the full potential in each of us, which in turn, contributes directly to our business success. We cannot afford to let anyone’s talents go to waste.
SDL Brokerage and Group Health Solutions is an equal employment/ affirmative action employer and is committed to providing a workplace that is free of discrimination of all types from abusive, offensive, or harassing behavior. Any employee who feels harassed or discriminated against should report the incident to their manager or to human resources.
Create a Culture of Open and Honest Communication
At SDL Brokerage and Group Health Solutions everyone should feel comfortable to speak his, her, or their mind, particularly with respect to ethics concerns. Managers have a responsibility to create an open and supportive environment where employees feel comfortable raising such questions. We all benefit tremendously when employees exercise their power to prevent mistakes or wrongdoing by asking the right questions at the right time.
SDL Brokerage and Group Health Solutions will investigate all reported instances of questionable or unethical behavior. In every instance where improper behavior is found to have occurred, the company will take appropriate action. We will not tolerate retaliation against employees who raise genuine ethics concerns in good faith.
For your Information, SDL Brokerage and Group Health Solutions’ whistleblower policy is as follows:
Employees are encouraged, in the first instance, to address such issues with their managers or the HR manager, as most problems can be resolved swiftly. If for any reason that is not possible or if an employee is not comfortable raising the issues with their manager or HR, the SDL Brokerage and Group Health Solutions’ Managing Director does operate with an open-door policy.
Management has the added responsibility for demonstrating, through their actions, the importance of this Code. In any business, ethical behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example. Again, ultimately, our actions are what matters.
To make our Code work, managers must be responsible for promptly addressing ethical questions or concerns raised by employees and for taking the appropriate steps to deal with such issues. Managers should not consider employees’ ethics concerns as threats or challenges to their authority, but rather as another encouraged form of business communication. At SDL Brokerage and Group Health Solutions, we want ethics dialogue to become a natural part of daily work.
Uphold the Law
SDL Brokerage and Group Health Solutions’ commitment to integrity begins with complying with laws, rules, and regulations where we do business. Further, each of us must have an understanding of the company policies, laws, rules and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or SDL Brokerage and Group Health Solutions policy, we should seek the advice from the resource expert. We are responsible for preventing violations of law and for speaking up if we see possible violations.
We are dedicated to ethical, fair, and vigorous competition. We will sell SDL Brokerage and Group Health Solutions’ products and services based on their merit, superior quality, functionality and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for SDL Brokerage and Group Health Solutions or the sales of its products or services, nor will we engage or assist in unlawful boycotts of particular customers.
It is important that we respect the property rights of others. We will not acquire improper means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution or alteration or other intellectual property.
We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals, or otherwise) any material nonpublic information with respect to SDL Brokerage and Group Health Solutions, its securities, business operations, plans, financial condition, results of operations or any development plan. We should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material nonpublic information.
Health and Safety
SDL Brokerage and Group Health Solutions is dedicated to maintaining a healthy environment. A safety manual has been designed to educate you on safety in the workplace. If you do not have a copy of this manual, please contact the HR department.
Avoid Conflicts of Interest
Conflicts of Interest
We must avoid any relationship that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of SDL Brokerage and Group Health Solutions may conflict with our own personal or family interests. We owe a duty to SDL Brokerage and Group Health Solutions to advance its legitimate interests when the opportunity to do so arises. We must never use SDL Brokerage and Group Health Solutions property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with SDL Brokerage and Group Health Solutions.
Here are some ways in which conflicts of interest could arise:
- Being employed (you or a close family member) by, or acting as a consultant to, a competitor or potential competitor, supplier, or contractor, regardless of the nature of the employment, while you are employed with SDL Brokerage and Group Health Solutions.
- Hiring or supervising family members or closely related persons.
- Serving as a board member for an outside commercial company or organization.
- Owning or having a substantial interest in a competitor, supplier, or contractor.
- Having a personal interest, financial interest or potential gain in any SDL Brokerage and Group Health Solutions transaction.
- Placing company business with a firm owned or controlled by SDL Brokerage and Group Health Solutions’ employee or their family.
- Accepting gifts, discounts, favors or services from a customer/potential customer, competitor or supplier, unless equally available to all SDL Brokerage and Group Health Solutions employees.
Determining whether a conflict of interest exists is not always easy to do. Employees with a conflict of interest question should seek advice from management. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, employees must seek review from their managers or their HR department.
Gifts, Gratuities and Business Courtesies
SDL Brokerage and Group Health Solutions is committed to competing solely on merit of our products and services. We should avoid any actions that create a perception that favorable treatment of outside entities by SDL Brokerage and Group Health Solutions was sought, received or given in exchange for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment or other benefits from persons or companies with SDL Brokerage and Group Health Solutions does or may do business. We will neither give nor accept business courtesies that constitute, or could be reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or policies of SDL Brokerage and Group Health Solutions or customers, or would cause embarrassment or reflect negatively on SDL Brokerage and Group Health Solutions’ reputation.
Accepting Business Courtesies
Most business courtesies offered to us in the course of our employment are offered because of our positions at SDL Brokerage and Group Health Solutions. We should not feel any entitlement to accept and keep a business courtesy. Although we may not use our position at SDL Brokerage and Group Health Solutions to obtain business courtesies, and we must never ask for them, we may accept unsolicited business courtesies that promote successful working relationships and good will with the firms that SDL Brokerage and Group Health Solutions maintains or may establish a business relationship with.
Employees who award contracts or who can influence the allocations of business, who create specifications that result in the placement of business or who participate in negotiation of contracts must be particularly careful to avoid actions that create the appearance of favoritism or that may adversely affect the company’s reputation for impartiality and fair dealing. The prudent course is to refuse a courtesy from a supplier when SDL Brokerage and Group Health Solutions is involved in choosing or reconfirming a supplier or under circumstances that would create an impression that offering courtesies is the way to obtain SDL Brokerage and Group Health Solutions’ business.
Meals, Refreshments, and Entertainment
We may accept occasional meals, refreshments, entertainment and similar business courtesies that are shared with the person who has offered to pay for the meal or entertainment, provided that:
- They are not inappropriately lavish or excessive
- The courtesies are not frequent and do not reflect a pattern of frequent acceptance of courtesies from the same person or entity.
- The courtesy does not create the appearance of an attempt to influence business decisions, such as accepting courtesies or entertainment from a supplier whose contract is expiring in the near future.
- The employee accepting the business courtesy would not feel uncomfortable discussing the courtesy with their manager or co-worker or having the courtesies known by the public.
Employees may accept unsolicited gifts, other than money, that conform to the reasonable ethical practices of the marketplace, including:
- Flowers, fruit baskets and other modest presents that commemorate a special occassion.
- Gifts of nominal value, such as calendars, pens, mugs, caps, and t-shirts (or other novelty, advertising or promotional items).
Generally employees may not accept compensation, honoraria or money of any amount from entities with whom SDL Brokerage and Group Health Solutions does or may do business. Tangible gifts (including tickets to a sporting or entertainment event) that have a market value greater than $100 may not be accepted unless approval is obtained from management.
Employees with questions about accepting business courtesies should talk to their managers or the HR department.
Offering Business Courtesies
Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon SDL Brokerage and Group Health Solutions. An employee may never use personal funds or resources to do something that cannot be done with SDL Brokerage and Group Health Solutions’ resources. Accounting for business courtesies must be done in accordance with approved company procedures.
Other than to our government customers, for whom special rules apply, we may provide nonmonetary gifts (i.e., company logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments or entertainment of reasonable value, provided that:
- The practice does not violate any law or regulation or the standards of conduct of the recipient’s organization.
- The business courtesy is consistent with industry practice, is in frequent in nature and is not lavish.
- The business courtesy is properly reflected on the books and records of SDL Brokerage and Group Health Solutions.
Set Metrics and Report Results Accurately
Accurate Public Disclosures
We will make certain that all disclosures made in financial reports and public documents are full, fair, accurate, timely and understandable. This obligation applies to all employees, including all financial executives, with any responsibility for the preparation for such reports, including drafting, reviewing and signing or certifying the information contained therein. No business goal of any kind is ever an excuse for misrepresenting the facts or falsifying records.
Employees should inform Executive Management and the HR department if they learn that information in any filing or public communication was untrue or misleading at the time it was made or if subsequent information would affect a similar future filing or public communication.
We create, retain, and dispose of our company records as part of our normal course of business in compliance with all SDL Brokerage and Group Health Solutions’ policies and guidelines, as well as all regulatory and legal requirements.
All corporate records must be true, accurate, and complete, and company data must be promptly and accurately entered in our books in accordance with SDL Brokerage and Group Health Solutions and other applicable accounting principles.
We must not improperly influence, manipulate or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of SDL Brokerage and Group Health Solutions’ books, records, processes or internal controls.
Promote Substance Over Form
At times, we are all faced with decisions we would rather not have to make and issues we would prefer to go avoid. Sometimes, we hope that if we avoid confronting a problem, it will simply go away.
At SDL Brokerage and Group Health Solutions, we must have the courage to tackle the tough decisions and make difficult choices, secure in the knowledge that SDL Brokerage and Group Health Solutions is committed to doing the right thing. At times this will mean doing more than simply what the law requires. Merely because we can pursue a course of action does not mean we should do so.
Although SDL Brokerage and Group Health Solutions’ guiding principles cannot address every issue or provide answers to every dilemma, they can define the spirit in which we intend to do business and should guide us in our daily conduct.
Each of us is responsible for knowing and adhering to the values and standards set forth in this Code and for raising questions if we are uncertain about company policy. If we are concerned whether the standards are being met or are aware of violations of the Code, we must contact the HR department.
SDL Brokerage and Group Health Solutions takes seriously the standards set forth in the Code, and violations are cause for disciplinary action up to and including termination of employment.
Confidential and Proprietary Information
Integral to SDL Brokerage and Group Health Solutions’ business success is our protection of confidential company information, as well as nonpublic information entrusted to us by employees, customers and other business partners. Confidential and proprietary information includes such things as pricing and financial data, customer names/ addresses or nonpublic information about other companies, including current or potential suppliers and vendors.
Use of Company Resources
Company resources, including time, material, equipment and information, are provided for company business use. Nonetheless, occasional personal use is permissible as long as it does not affect job performance or cause disruption to the workplace.
Employees and those who represent SDL Brokerage and Group Health Solutions are trusted to behave responsibly and use good judgement to conserve company resources. Managers are responsible for their resources assigned to their departments and are empowered to resolve issues concerning their proper use.
Generally, we will not use company equipment such as computers, copiers, scanners and fax machines in the conduct of outside business or in support of any religious, political or other outside daily activity, except for company-requested support to nonprofit organizations. We will not solicit contributions nor distribute non- work related materials during work hours.
In order to protect the interests of SDL Brokerage and Group Health Solutions’ network and our fellow employees, SDL Brokerage and Group Health Solutions reserves the right to monitor or review all data and information contained on an employee’s company-issued computer or electronic device, the use of the internet or SDL Brokerage and Group Health Solutions’ intranet. We will not tolerate the use of company resources to create, access, store, print, solicit or send materials that are harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate.
Questions about the proper use of company resources should be directed to your manager.
SDL Brokerage and Group Health Solutions is a high-profile company in our community, and from time to time, employees may be approached by reporters and other members of the media. In order to ensure that we speak with one voice and provide accurate information about the company, we should direct all media inquiries to the Compliance and Media Officer, Rob Bujan. No one may issue a press release without first consulting with the Compliance and Media Officer, Rob Bujan.
Social Media/ Networking
Make sure you are always honest and accurate when posting information or news, and if you make a mistake, correct it quickly. Remember that the internet archives almost everything; therefore, even deleted postings can be searched. Never post any information or rumors that you know to be false about SDL Brokerage and Group Health Solutions or our business partners, fellow associates, members, customers, suppliers, or people working on behalf of SDL Brokerage and Group Health Solutions or competitors.
Post only appropriate and respectful content
- Maintain the confidentiality of SDL Brokerage and Group Health Solutions trace secrets and private or confidential information. Trade secrets may include information regarding the development of systems, processes, products, know-how and technology. Do not post internal reports, policies, procedures or other internal business-related confidential communications.
- Respect financial disclosure laws. It is illegal to communicate or give a “tip” on inside information to others so that they may buy or sell stocks or securities. Such online conduct may also violate the Insider Trading Policy.
- Do not create a link from your blog, website, or other social networking site to a SDL Brokerage and Group Health Solutions website without identifying yourself as a SDL Brokerage and Group Health Solutions associate.
- Express only your personal opinions. Never represent yourself as a spokesperson for SDL Brokerage and Group Health Solutions. If SDL Brokerage and Group Health Solutions is a subject of the content you are creating, be clear and open about the fact that you are an associate and make it clear that your views do not represent those of SDL Brokerage and Group Health Solutions, fellow associates, members, customers, suppliers or people working on behalf of SDL Brokerage and Group Health Solutions. If you do publish a blog or post online related to the work you do or subjects associated with SDL Brokerage and Group Health Solutions, make it clear that you are not speaking on behalf of SDL Brokerage and Group Health Solutions. It is best to include a disclaimer such as “The postings on this site are my own and do not necessarily reflect the views of SDL Brokerage and Group Health Solutions.
Do the Right Thing
Several key question can help identify situations that may be unethical, inappropriate, or illegal. Ask yourself:
- Does what I am doing comply with the SDL Brokerage and Group Health Solutions’ guiding principles, Code of Conduct and company policies?
- Have I been asked to misrepresent information or deviate from normal procedure? Would I feel comfortable describing my decision at a staff meeting?
- How would it look if it made the headlines?
- Am I being loyal to my family, my company and myself?
- What would I tell my child to do?
- Is it the right thing to do?
Compliance & Media Contact: