Integrity

Code of Conduct

Each job at Highmark Casualty Insurance Company carries with it special considerations. Our Code of Business Conduct provides a guide to appropriate decision-making when we find ourselves in specific work situations. The Code consists of policies each of us must follow as our jobs dictate.

The Code's policies are organized into the following Guideposts:

I. Maintain respectful and dignified personal relationships
II. Ensure a safe and healthy work environment
III. Ensure proper use of company assets
IV. Keep accurate and timely records
V. Execute contracts efficiently and accurately
VI. Avoid personal conflicts of interest
VII. Protect trade secrets, competitive and medical information
VIII. Ensure appropriate customer and supplier relationships
IX. Ensure compliance with intellectual property laws and software license agreements.

Our Code of Business Conduct reflects the company's commitment to the highest standards of ethical business conduct. This Code, which is part of our broader Integrity Process, helps us do our jobs better by providing guidance in making day-to-day decisions.

Just as a map does not identify every street and alley, it is important to recognize that our Code of Business Conduct, although detailed, cannot address every conceivable situation where we may need ethical guidance. However, the Integrity Process — the Highmark Casualty Insurance Company ethical framework — values teamwork, pride and excellence in attaining our goals. In short, we care not only about the end result but how it was attained.

Guidepost I:
Maintain respectful and dignified personal relationships
Highmark Casualty Insurance Company’s policy is to provide equal employment to qualified individuals regardless of their race, color, sex, religion, national origin or age. Differences in backgrounds that each individual brings to Highmark Casualty Insurance Company are to be respected, as it is those differences that bring to us an essential value. Current and prospective employees can be assured that the work environment at Highmark Casualty Insurance Company promotes fairness and equal opportunity in the employment process. At Highmark Casualty Insurance Company, equal opportunity is provided in all aspects of the employment process, including recruitment, hiring, work assignment, promotion, transfer, termination, wage and salary administration and selection for training. Highmark Casualty Insurance Company employees are expected to treat fellow employees, visitors and all those they encounter with professional respect and courtesy, regardless of their position, age, race, sex, disability or other differences of a personal nature that do not relate to business matters. Therefore, sexual harassment — physical, written or verbal — will not be tolerated in the workplace. Highmark Casualty Insurance Company also provides a work environment that helps prevent discrimination against a qualified individual with a disability in respect to any offer, condition, or privilege of employment. All applicants and employees are assured that all information regarding disability will be kept completely confidential.

Guidepost II:
Ensure a safe and healthy work environment
Highmark Casualty Insurance Company is committed to providing a safe and healthy environment for employees and visitors. Highmark Casualty Insurance Company will not tolerate actions or threats by anyone that disrupts business, or places customers, employees, suppliers or visitors at risk of harm. Accordingly, it is the policy of Highmark Casualty Insurance Company that all employees have not only the right but also the obligation to report any conditions that could create a hazard in the work site.

Guidepost III:
Ensure proper use of company assets
At Highmark Casualty Insurance Company, all employees share a common responsibility in assuring company assets are used efficiently in achieving its goals. Highmark Casualty Insurance Company's assets not only include such things as equipment, inventory, corporate funds, and office supplies but also intangible items such as concepts, business strategies and plans, financial data, intellectual property rights and other information used in Highmark Casualty Insurance Company’s business. By using these assets efficiently, we can deliver our products and services more cost effectively.

Guidepost IV:
Keep accurate and timely records
Maintaining accurate and complete records is vital to the success of our business because Highmark Casualty Insurance Company and its customers depend on this information to make sound decisions. Good business practice and government regulations require Highmark Casualty Insurance Company to keep its books and records accurately to reflect the true nature of the transactions represented. Consequently, in all of our operations, it is against company policy, and possibly illegal, for any employee to cause our books to be inaccurate or misleading in any way for any reason.

Guidepost V:
Execute contracts efficiently and accurately
Our customers, whether they are government or commercial business, expect our products and services will meet the contractual requirements. Highmark Casualty Insurance Company carries out all business contracts in accordance with the terms of those contracts. Highmark Casualty Insurance Company strives to ensure that accurate and complete information is provided when negotiating and administering a contract. Highmark Casualty Insurance Company is committed to strict compliance with all federal and state laws, regulations, and contract terms and conditions applicable to our business. As a government contractor, Highmark Casualty Insurance Company is aware that the government can exclude, debar, or sanction any individual or the whole company from doing business with the government when convicted of a health care related misdemeanor or felony. Therefore, it is the obligation of every employee to provide accurate and complete statements to the government. It is a violation of federal laws and against company policy for any employee to knowingly make a false or misleading statement.

Guidepost VI:
Avoid personal conflicts of interest
Conflicts of interest arise when an employee's outside personal interests influence business decisions. Employees of Highmark Casualty Insurance Company shall avoid situations where personal interests may conflict with the interests of Highmark Casualty Insurance Company, or where the judgment or decision-making process may be impaired to affect our buying or selling decisions.

Guidepost VII:
Protect trade secrets, competitive and medical information
Competitive information entrusted to Highmark Casualty Insurance Company by customers and suppliers shall be protected and used appropriately at all times. We observe all federal and states laws regarding the protection of patients' confidential medical information. Highmark Casualty Insurance Company employees are expected to actively safeguard the company's trade secrets and confidential information, such as medical information, from improper disclosure.

Guidepost VIII:
Ensure appropriate customer and supplier relationships
Highmark Casualty Insurance Company strives to maintain straightforward business relationships with customers and suppliers. These relationships should be based on cost and the quality of the product and/or service, rather than on personal relationships. It is the employees' obligation to guard against any behavior, including the receipt of or offering of gifts, meals or other gratuities that could be perceived as improperly intended to influence a business decision. As a government contractor, Highmark Casualty Insurance Company observes all anti-kickback laws and regulations. Under no circumstance will Highmark Casualty Insurance Company employees offer money, gifts, services, entertainment, or anything of value, directly or indirectly, to any government official or employee. Suppliers are encouraged to respect and observe our gift policy and avoid offering excessive gifts and entertainment that may place our employees in an uncomfortable position. Similarly, Highmark Casualty Insurance Company expects its customers to select its products because they represent the best value in the market. Therefore, Highmark Casualty Insurance Company’s employees are discouraged from offering any gift or entertainment that is not incidental to a business relationship.

Guidepost IX:
Ensure compliance with intellectual property laws and software license agreements
Highmark Casualty Insurance Company expects employees to understand and comply with the rules related to the use of copyrighted and trademarked materials. It is critical that all Highmark Casualty Insurance Company employees understand the rules governing the use of intellectual property and abide by the company's obligation under the software licensing agreements to which it is bound.