DCPG’s Code of Conduct
- Introduction from President and CEO
- A Mission with Momentum
- Ethical Conduct: Living Up To Expectations
- Professional Relationships with Business Partners & Vendors
- Work Environment
- Succeeding at DCPG
- Privacy and Security Regulations
- Acquiring and Using Sensitive Information
- Financial Disclosure and Management
- Media Relations Policy
- Conflicts of Interest
- Political Activities and Contributions
- Social Responsibility and Civic Activities
- Code of Conduct Waivers
Introduction from the President and CEO
The Dental Care Plus Holding Company and its subsidiaries, known collectively as The Dental Care Plus Group (DCPG), owes its success to delivering on its promises and building a reputation that has become its most valuable asset. The Dental Care Plus Group thrives through internalizing a simple but timeless business truth: high performance standards are only sustainable when backed by commitment to integrity, fairness and good judgment.
DCPG's vision for ongoing growth requires a collective ethical compass honored by every DCPG employee and member of the board of directors. A written Code of Conduct ensures that all employees understand their role in upholding the Company's reputation. Public dissemination of the Code of Conduct ensures that all stakeholders — shareholders, dentists, plan members and the employers who purchase our plans — understand the standards to which they should hold every employee and board member.
All DCPG employees and board members are expected to review the Code of Conduct and to refer to its guidelines as necessary. It is intended to articulate the core ideas that drive our behavior and decisions.
As a "living document," the Code of Conduct will never be finalized. A formal review will be conducted by the end of the second quarter each fiscal year, and changes will be considered whenever necessary to ensure its ongoing relevancy. Employees with suggestions for enhancing or clarifying any aspect of the Code of Conduct should submit their comments in writing to the President/CEO and copy their direct supervisor and/or department head.
I want to extend my thanks to all of the senior managers and members of the board of directors who participated in developing the DCPG Code of Conduct.
— Anthony A. Cook, M.B.A., M.S. — President and CEO
A Mission with Momentum [back to top]
In 1986, several leading dentists practicing in the Greater Cincinnati and Northern Kentucky community decided to test the adage: the best defense is a strong offense.
DCPG's founding shareholder dentists recognized that managed care was inevitable and chose to exert influence on their market by creating a competitive managed care plan that works — for dentists, for members, for employers and for shareholders. The Dental Care Plus Group's mission — then and now — is to be a competitive, professional and qualified network of people providing competitive, quality dental managed care services in the most cost-effective and responsive manner. DCPG strives to maintain the benefits of the Independent Practice Association (IPA) concept, including quality care, fee-for-service, and autonomy in dental practices.
The mission is realized day-to-day through a business philosophy that balances the interests of all key stakeholders: shareholders, dentists, members and employers. All stakeholders require and deserve our commitment and consideration of their interests. We pride ourselves on providing the best possible service to our members and business partners, and understanding that without their support and trust, our business would cease to exist.
Ethical Conduct: Living Up to Expectations [back to top]
The DCPG brand is built upon persistent adherence to dependability, honesty and thorough knowledge of the industry and markets in which we conduct business. We strive every day to be a Company with whom other businesses want to work, to be the Company against which our competitors are benchmarked, to be a Company open to feedback and a partner that is responsive to our stakeholders' needs in a dynamic economy. We are upfront about our capabilities, deliver upon our promises and are courteous in all our interactions. The brand is sustained every day by the action and decisions of every employee.
All DCPG employees are held to the same high standard of conduct and performance. The mere appearance of impropriety can be damaging to our reputation and image. Core areas of conduct include but are not exclusive to:
- Dealing consistently and honestly with all clients, members and providers.
- Handling requests of clients, members and providers promptly and cheerfully.
- Exercising tact, patience and courtesy at all times.
- Taking personal interest and initiative in solving problems.
- Protecting the rights and confidentiality of clients, members and providers, and assuring that health information protected under the provisions of the Health Insurance Portability and Accounting Act (HIPAA), the American Recovery and Reinvestment Act of 2009 (ARRA) and the Health Information Technology for Economic and Clinical Health Act (HITECH) is never violated.
Marketing, advertising and formal communications about DCPG, its products and its capabilities are never misleading. DCPG believes that great thinking, quality products and commitment to service provide ample competitive advantage. We do not claim what we have not earned nor do we promise what we cannot deliver.
Occasionally, employees face ethical questions in the course of their work. Most situations offer several possible courses of actions. Making the right decision should always include careful consideration of what is right.
DCPG employees are asked to apply the "Front Page" test in these situations. In other words, if your decision appeared as a front-page story in your local newspaper — a newspaper sure to be read by your family, colleagues, friends and neighbors — would you proceed with the decision or choose another course?
Another question to consider when facing a unique ethical dilemma unlikely to be noticed or repeated: "What if I did this 100 times rather than once?" If the exposure or the consequences of a potential course of action increases with repetition, then DCPG employees should search for an alternative.
Reporting Unethical Activity
Employees with questions or concerns about unethical conduct, or who feel they have knowledge of a potential violation of DCPG's Code of Conduct must report the incident in question. Employees have several options for seeking clarification on the Code of Conduct's application and for reporting violations. Based upon the nature of the incident and the anticipated consequences of reporting it, the employee should choose the option with which he or she is most comfortable.
- Employees may choose to speak with their immediate supervisor or department head.
- If employees are uncomfortable speaking with an immediate supervisor or department head, or feel that the issue was not sufficiently resolved through this channel, they may speak to company officers, including the CEO and CFO.
- Employees who feel that their questions or concerns are inadequately addressed by senior management, or who wish to report their issue anonymously, may submit their questions or concerns in writing to one of the following board members: chairman of the audit committee or chairman of the DCPG board of directors.
All submissions will be kept confidential. Retaliation for reporting unethical activity is prohibited. Employees who retaliate are subject to discipline, including discharge.
DCPG employees are subject to disciplinary action for violating DCPG's Code of Conduct, SEC regulations, state regulatory requirements, or privacy and security policies and procedures. Violations can result in disciplinary action up to and including discharge.
Professional Relationships with Business Partners and Vendors [back to top]
Employees of DCPG must not solicit nor accept for personal benefit directly or indirectly any gift, loan or any item of substantial monetary value from a person, vendor or company with whom DCPG does business or who is seeking to do business with DCPG. Employees should always check with their department head before giving or receiving any gifts or favors from persons outside the Company.
DCPG strives for long-term mutually-beneficial relationships with competent, trustworthy and service-oriented vendors. Accomplishing this objective requires DCPG to behave honorably and professionally toward vendors as well as demanding similar consideration from vendors.
Work Environment [back to top]
DCPG's reputation for exceptional customer service relates directly to the respect that DCPG fosters among its employees. Harmonious, productive working relationships foster strong, consistent performance and employee loyalty as well as respect for DCPG stakeholders. DCPG's policies that affect the employee's work environment reflect high ethical standards and are in compliance with Federal and State laws, where applicable.
Succeeding At DCPG [back to top]
DCPG is open to employee feedback regarding ways to further improve upon the Company's work environment and benefits to promote the long-term retention of quality employees. In addition, DCPG has a long history of benefiting from efficiencies and quality-improvement measures initiated by staff working in every department at all levels of the Company.
DCPG strives to be an "employer of choice" within its industry and to attract quality employees qualified to contribute their talent and expertise toward DCPG growth and profitability. Maintaining a quality work environment is, long-term, the company's best recruitment strategy.
Privacy and Security Regulations [back to top]
To comply with regulations of the Health Insurance Portability & Accounting Act of 1996 (HIPAA), the American Recovery and Reinvestment Act of 2009 (ARRA) and the Health Information Technology for Economic and Clinical Health Act (the HITECH Act), together taken as the privacy and security regulations, all employees are trained on provisions of these regulations as they pertain to his or her particular job responsibilities.
DCPG employees are subject to disciplinary action for violating these privacy and security policies and procedures. Violations that jeopardize the privacy or security of protected health information (PHI) are particularly serious and can result in disciplinary action up to and including discharge.
Acquiring and Using Sensitive Information [back to top]
Employees must maintain the privacy of non-public information on any Company provided to DCPG in the course of business.
DCPG does not encourage nor condone improper methods to obtain competitive proprietary information, including inducing or attempting to induce another company's present or former employees or third parties to disclose sensitive or proprietary information.
DCPG employees are expected to protect the assets of the Company and use them efficiently to advance the interest of the Company. Those assets include tangible assets and intangible assets, such as confidential information of the Company. Employees of DCPG must not divulge non-public proprietary or sensitive information about DCPG during or after their tenure with the Company. This provision extends to ideas, information and data. Disclosure of copyrighted material, trade secrets, customer lists, marketing plans, manuals, rating schedules, reimbursement schedules and other materials developed for business use is strictly prohibited and could result in legal action.
DCPG conducts background searches on all prospective employees. Federal law and/or state insurance regulations prohibit individuals convicted of a felony involving breach of trust or dishonesty from holding an insurance license.
Financial Disclosure and Management [back to top]
All filings with the SEC and the ODI are public record. Copies may be obtained through these agencies or through a written request to the DCPG Chief Financial Officer. Several filings are also available in PDF form or through an Internet hyperlink on the Company's website under the "About Us - Shareholders" tab.
DCPG shareholders receive regular updates on the Company's progress toward performance goals, business decisions and rationale, product designs and implications, and operational issues. In addition, shareholders receive an annual report and audited financial statement approximately 30 days prior to the annual shareholders meeting.
DCPG shareholders have full access to members of the board of directors and the Company CEO/President whenever they have questions or feedback for the Company. Forums are held throughout the year for shareholders to attend meetings with DCPG management. In addition, owners of Common A Shares have the opportunity to serve on various subcommittees and task groups charged with investigating various business policies and decisions, and advising the board of directors.
Media Relations Policy [back to top]
DCPG employees should be acquainted with and comply with the Company's approved Media Protocol. All employees are provided with a copy of the Media Protocol to review and sign upon joining the company. A copy of the protocol is housed under the folder on the company shared drive called Code of Conduct & Media Protocol. Any other questions about the protocol should be directed to the Director of Marketing and Corporate Communications.
The primary purpose of the protocol is to ensure that only approved spokespersons provide information or comment to any media outlet regarding DCPG policies, procedures or performance. The Media Protocol is in place to ensure that information released through these public vehicles is accurate, verified and professionally handled. The Protocol also alleviates employees without adequate information or perspective, or who are uncomfortable with the pressure of responding to media inquiries related to the company.
Please direct all media inquiries to the Director of Marketing and Communications at 513-554-1100, or here. In the absence of the Director of Marketing and Communications, all inquiries and statements should be reviewed by the DCPG CEO/President.
Conflicts of Interest [back to top]
DCPG board members and employees are expected to act in the best interests of DCPG and its shareholders throughout their tenure. Knowledge gained about DCPG, its partners or its competitors is not to be used for personal benefit or for harm against DCPG, whether intended or otherwise.
Any outside business interest that weakens or divides an employee's interests from the interests of DCPG is a conflict. Any outside business interests which distract the employee or board member from fulfilling his or her job requirements is a conflict.
Any potential conflicts of interest are to be reported immediately to a human resources representative (Michael Waldman, Controller; Nelson Seip, Employers Resource Association Consultant), the employee's immediate supervisor or the DCPG President/CEO.
It is impossible to provide an exhaustive list of potential conflicts, so employees are advised to consult with their immediate supervisor, the human resources representative or the DCPG President/CEO if they believe that their actions within or outside of employment could be a conflict of interest. The following list provides examples of situations that may present a conflict of interest:
- Ownership or significant financial interest by an employee or member of an employee's immediate family in a business enterprise doing business with or seeking to do business with or competing with DCPG;
- Business interests which adversely impact the employee's job performance or which involve the use of DCPG's equipment, supplies, facilities or name are prohibited;
- Serving as a director, officer, partner, consultant or in any other key role in any outside enterprise doing business or seeking to do business with DCPG;
- Approving insurance applications, handling underwriting transactions, or handling claims for yourself or for members of your family;
- Maintaining outside employment that interferes with scheduled work for DCPG, impairs the employee's effectiveness, results in publicity adverse to DCPG or could be construed as a conflict with DCPG interests;
- Any arrangement or circumstance, including family or other personal relationships, which might prevent the employee from acting in the best interests of DCPG;
- A business opportunity derived from DCPG or based upon confidential information not available to the public that could result in personal gain or cause adversity to DCPG interests.
Political Activities and Contributions [back to top]
DCPG does not directly endorse or contribute funds toward political candidates. DCPG does belong to industry associations which monitor legislative, judicial and executive action on the state and federal level. These associations engage in lobbying activities that address the general interests of the insurance industry or dental insurance. DCPG also affiliates with other insurance carriers with similar goals and interests to assess the impact of proposed federal or state laws or regulations, and to offer input on potential alternatives or the implementation of related legislation.
DCPG encourages employees to follow current events, vote and exercise the rights of their citizenship. However, employees are discouraged from advocating their political views during business hours or in Company-sponsored forums. Polite discussion is permitted and often unavoidable in business environments, but heated exchanges or insulting remarks that damage working relationships and disrupt work are unacceptable. In addition, political activity during business hours, including soliciting donations, gathering signatures for petitions or disseminating political promotional materials such as flyers, bumper stickers, etc. is strictly prohibited.
Social Responsibility and Civic Activities [back to top]
Successful businesses have an obligation to support the communities which have fostered their success. For this reason, DCPG regularly sponsors and supports nonprofit activities which benefit local schools, youth activities and other worthwhile community service. In addition, DCPG supports nonprofit efforts related to advancement of medical/dental research and health awareness.
Criteria for determining support and the form that support will take are used to evaluate all requests for support. All sponsorship and underwriting requests should be forwarded to the Director of Marketing and Corporate Communications, who will evaluate the proposals.
DCPG employees are encouraged to participate in nonprofit activities as time allows. Permission to pursue these activities during business hours must be submitted to the employees' direct supervisor and/or department head in advance for approval.
Code of Conduct Waivers [back to top]
Each DCPG employee is expected to adhere at all times to this Code of Conduct. Only the Board of Directors or a committee designated by the Board of Directors (currently the Corporate Affairs Committee) shall have the authority to approve any deviation or waiver from this Code. It is recognized that there will be questions about the application of the policies to specific activities and situations. In cases of doubt, all employees are expected to seek clarification and guidance from a member of the executive team, with the Board of Directors or a committee designated by the Board being the final determining authority if there is uncertainty regarding appropriate action.