Corporate Responsibility & Ethical Conduct

1) Our Commitment to Ethical Conduct

Ethics guide every interaction — how we deliver services, treat one another, manage resources, and represent our brand in the community.
Corporate responsibility, for us, means balancing business sustainability with the wellbeing of people and the communities we serve.

Our Code of Conduct and related policies set the framework for professional behavior. They apply equally to leadership, staff, contractors, volunteers, vendors, and board members.
Every individual connected to our organization shares a duty to uphold these values and report any behavior that undermines them.

2) Ethical Codes of Conduct

We maintain comprehensive written standards in the following areas:

1. Business Practices

We act honestly and lawfully in all operations — from billing and documentation to community engagement. Records must be accurate, truthful, and secure.
Misrepresentation, misuse of resources, or conflicts of interest are strictly prohibited.

2. Marketing and Communications

All communications are accurate, non-coercive, and culturally sensitive.
Images or stories used publicly require consent and must preserve dignity and privacy.

3. Contractual Relationships

Partnerships are built on fairness and clarity.
Every contract outlines mutual responsibilities and avoids conflicts of interest or hidden incentives.

4. Conflicts of Interest

Personal or financial interests that could compromise impartial judgment must be disclosed immediately.
Staff may not participate in decisions where a conflict exists.
We maintain a Conflict-of-Interest Disclosure Log to ensure transparency.

5. Use of Social Media

Online communication carries the same professional expectations as in-person interactions.
Confidential information, internal images, or comments about persons served are never shared publicly.
We encourage positive advocacy while protecting privacy.

3) Service-Delivery Ethics (CARF 1.A.6 a–e)

Service ethics protect those we serve and preserve professional integrity.
This section directly fulfills all CARF 1.A.6 requirements and applies to every employee, volunteer, and contractor involved in service delivery.

(a i–iii) Exchange of Gifts, Money, and Gratuities

To prevent favoritism or coercion:

• Prohibited: accepting or offering cash, checks, digital transfers, gift cards, tips, or any item of monetary value.
• Permitted with limits: small non-cash tokens (e.g., thank-you cards, handmade crafts) valued at ≤ $10 each and ≤ $25 per person per year, only with supervisor approval and documentation in the Gift/Conflict Log.
• All offered gifts, even when declined, are recorded for transparency.
  These safeguards ensure relationships remain professional, equitable, and based solely on service quality.

(b) Personal Fundraising

Staff may not use work relationships to solicit donations, sell goods, or promote personal or outside causes.
This includes raffles, product sales, or online campaigns shared with clients or vendors.
Organizational fundraising may occur only through approved channels that respect participants’ boundaries and avoid undue influence.

(c) Personal Property

We respect the personal property of every person we serve.
Employees may not borrow, lend, store, purchase, or transport clients’ belongings.
If immediate safety requires temporary safeguarding — for example, removing hazardous objects — staff must:

1. Complete a Property Log detailing item description and condition.
2. Obtain two staff signatures.
3. Store the item in a secure, designated location.
4. Return it with a signed receipt.
   This process ensures accountability and protection of client rights.

(d) Professional Boundaries

Boundaries preserve trust and safety.
Staff maintain clear professional relationships and avoid dual roles that could compromise objectivity.
Examples of prohibited conduct include:

• Providing off-duty transportation;
• Personal loans or gifts;
• Connecting on social media;
• Romantic or financial relationships;
• Unscheduled home visits outside the care plan.
  If a boundary concern arises, the staff member must seek guidance from their supervisor or Compliance Officer before acting.

(e) Witnessing of Legal Documents

Witnessing is permitted only when authorized by policy and law.
Steps include:

1. Supervisor approval prior to witnessing.
2. Verification of signer’s identity with photo ID.
3. Completion of a Witnessing Form documenting date, reason, and parties present.
4. Referral to a notary when required by law.
5. Clear disclaimer that staff cannot offer legal advice.
   This process ensures that clients receive proper support without risk of undue influence or liability.

Together, these five components meet all requirements of CARF 1.A.6 (a–e) by regulating gifts and gratuities, personal fundraising, property handling, boundaries, and document witnessing in a way that is transparent, documented, and protective of client welfare.

4) Reporting & Accountability Framework

Ethics only matter when enforced.
We foster an environment where everyone feels safe raising concerns.
Reports can involve suspected fraud, harassment, safety issues, or any behavior inconsistent with our Code of Conduct.

Core Principles

• No Reprisal: No one will suffer retaliation for reporting in good faith.
• Confidentiality: Information is shared only on a need-to-know basis.
• Fair Process: All reports are acknowledged, reviewed, investigated, and resolved promptly.
• Transparency: Investigation outcomes drive training and policy updates.

5) Education & Awareness

Ethical awareness begins with onboarding and continues throughout employment.
Our training includes:

• New-Hire Orientation: introduction to all ethical codes, privacy rules, and compliance reporting options.
• Annual Refresher Courses: updated with new laws, policies, and real-world examples.
• Scenario-Based Exercises: staff practice identifying conflicts of interest, reporting misconduct, and maintaining boundaries.
• Stakeholder Sessions: contractors, vendors, and partners receive summaries of relevant codes and attest to compliance.
• Client Education: persons served and families learn about their rights, complaint procedures, and advocacy supports.

6) Advocacy for Persons Served

Our services are built on respect, empowerment, and inclusion.
We:

• Center each individual’s goals and preferences in treatment and planning.
• Provide language interpretation and disability accommodations upon request.
• Offer materials in plain language and accessible formats.
• Promote independence and informed choice.
• Link clients to community resources such as housing, education, job training, and transportation.
• Encourage feedback through surveys and advisory councils.

Advocacy is not an extra service — it is a responsibility embedded in everything we do.

7) Corporate Citizenship

We aim to improve the communities that sustain us.
Our initiatives include:

• Partnering with local nonprofits on health, housing, and food-security programs.
• Hosting educational events on wellness, harm-reduction, and public safety.
• Supporting caregiver and youth mentorship efforts.
• Implementing environmentally responsible practices in facilities and purchasing.
• Participating in citywide boards and coalitions focused on accessibility and equity.

Every employee contributes to community wellbeing through volunteerism, stewardship, and ethical representation.

8) Governance & Transparency

Ethics are reinforced through oversight.
Executive leadership and governing bodies receive quarterly compliance reports summarizing:

• Training completion rates;
• Audit findings and resolutions;
• Incident trends and corrective actions;
• Policy updates and new regulations.

Findings inform organization-wide improvements to safety, quality, and fairness.

9) Stakeholder Engagement

Stakeholders are our partners in accountability.
We gather input through satisfaction surveys, advisory groups, community meetings, and open-door communication with leadership.
Feedback leads directly to policy changes and enhanced service quality.

10) Non-Retaliation Policy

Everyone has the right to raise a concern without fear.
Any act of intimidation, discipline, or retaliation against a good-faith reporter will be treated as a separate compliance violation and investigated immediately.
Leaders are expected to model openness and encourage reporting.

11) Continuous Improvement

Ethical conduct evolves with our environment.
We conduct annual reviews of our Code of Conduct, evaluate training effectiveness, and incorporate lessons from audits and stakeholder feedback.
Our goal is not only compliance — but excellence.

12) Corporate Compliance Oversight & Reporting

Designated Corporate Compliance Officer

Vernon Holmes
Corporate Compliance Officer (Designee)
Phone: (443) 452-3718
Email: legal@enterprisemgmtinc.com
Mailing Address: Corporate Compliance Office, 3310 Eastern Avenue, Baltimore, MD 21224

Role & Responsibilities

The Corporate Compliance Officer:

• Oversees the Corporate Compliance Plan and ensures its consistent application.
• Monitors adherence to federal, state, and accreditation requirements.
• Investigates reports of fraud, waste, abuse, or ethical breaches.
• Maintains a secure Compliance Log tracking all cases, actions, and timelines.
• Provides compliance education and awareness activities.
• Reports findings to executive leadership and governance quarterly.
• Coordinates with auditors, legal counsel, and regulators as needed.

How to File a Compliance Report

Anyone — client, employee, contractor, or community member — may report concerns confidentially or anonymously:

1. Online:
   Scroll to the bottom of this page and click “Report a Compliance Violation.”
   Complete the secure form and upload any supporting documents.
2. Email: legal@enterprisemgmtinc.com
3. Phone: (443) 452-3718 (M-F 8 a.m.–5 p.m. ET)
4. Mail or In-Person: 3310 Eastern Avenue, Baltimore MD 21224

Reports go directly to the Corporate Compliance Officer and are handled discreetly.

Response Timeframes

If regulations require faster resolution, those timelines take priority.
For complex cases, status updates are provided every 30 days until completion.

Investigation Outcomes & Corrective Actions

After investigation, actions may include:

• Targeted retraining or supervision.
• Policy or procedural updates.
• Disciplinary measures or contract termination.
• Process redesign to prevent recurrence.
• Self-reporting to external authorities when required.

Every corrective action is documented and verified before case closure.

Confidentiality & Recordkeeping

All compliance records are securely maintained in restricted systems.
Identifying information is protected, and access is granted only to personnel directly involved in resolution.
Data is retained in accordance with legal, regulatory, and accreditation mandates.

Annual Review & Public Accountability

The Compliance Officer compiles an annual summary describing major compliance themes, corrective actions, and improvement initiatives.
While individual reports remain confidential, aggregate trends are shared with stakeholders to demonstrate transparency and continual progress.