Training

Code of Conduct Training

The Company's Code of Conduct Distribution and Training Policy, EC.011, requires each HCA employee to receive Code of Conduct training. One hour of orientation training regarding our Code of Conduct, A Tradition of Caring, is required within thirty (30) days of becoming a covered person. During the orientation training, individuals will review the Code of Conduct in detail and acknowledge their understanding that it represents mandatory policies and agree to abide by it. One hour of Code of Conduct training is required annually (i.e., refresher training).

Compliance Training

In addition to training regarding the Company's Code of Conduct, employees are required to receive "compliance training" relative to their job responsibilities.  For example, individuals who perform billing services, receive billing compliance training.  Each Responsible Executive is expected to determine what training is needed within his or her area of compliance risk and to then develop and disseminate that training.

Training is delivered through a number of methods including webcasts, online courses and instructor-led sessions.  All training is tracked in the Company's Learning Management System.

Other Methods of Communication

Several methods of communication are used both internally and externally to promote and discuss the Company's ethics and compliance program. Two of the methods of external communication are speeches and articles. Methods of internal communication include a robust Intranet site, newsletters for facility Ethics and Compliance Officers (ECOs), periodic ECO Conference calls and webcasts, and Compliance Alerts.