In October 1997, HCA announced the development of the Ethics and Compliance Department (EC Department) and Alan Yuspeh was named Senior Vice President for Ethics [now Senior Vice President and Chief Ethics and Compliance Officer], Compliance and Corporate Responsibility. The department oversees the development and implementation of a comprehensive corporate Ethics and Compliance Program.

The Ethics and Compliance Program Includes:

1. Articulating standards of compliance and ethical conduct through a Code of Conduct and a series of company Policies and Procedures.
    
2. Creating awareness of these standards among everyone in the company through high quality ethics training, compliance training, and other ongoing communication efforts.
    
3. Providing a means to report exceptions (i.e., possible misconduct). We maintain an Ethics Line (1-800-455-1996) to receive reports from anyone who is aware of a violation of our Code of Conduct or Policies and Procedures. This line is answered at all times.
    
4. Monitoring and auditing performance in areas of compliance risk to ensure that established policies and procedures are being followed and are effective.
    
5. Establishing organizational supports, including necessary committees, responsible executives and facility ethics and compliance officers, for this entire effort.
    
6. And undertaking other efforts, such as clinical ethics and pastoral care services.