
Our Board is also subject to a Board Code of Ethics and a Whistleblower Policy Board Conflict of Interest Policy and Disclosure Statement. The Audit and Compliance Committee has established a These documents are intended to focus the Board and each Whistleblower Policy that includes our confidential and director on areas of ethical risk, provide guidance to directors anonymous reporting helpline, designed to promote open to help them recognize and deal with ethical issues, and to communication of concerns regarding potentially illicit or illegal promote honest and ethical conduct, including the handling of business practices and conduct, as well as provide reassurance actual, apparent or potential conflicts of interest between that any individual making a report will be protected from personal and professional relationships. For more information discrimination, retaliation, harassment or other reprisals for on the code and policy, please see the Investors-Governance raising concerns regarding potentially inappropriate conduct. Documents section of our website. For information, please see our Whistleblower Policy. Education, Awareness and Acknowledgments Intellectual Property and Competitive Behavior Employees complete an interactive We offer our members a range of products to which we have course that provides an overview intellectual property rights, including online services, best of our Code as part of our annual practices content, databases, electronic tools, web-based compliance education. The CY2020 100% applications, performance metrics, business methodologies, course included compliance topics proprietary algorithms, software products and consulting of employees completed such as conflict of interest, ethical services deliverables. We protect our intellectual property by our annual compliance leadership, information security, relying on federal, state and common law rights, as well as education. insider trading and social media. contractual arrangements. For more information, please see During CY2020, 100% of employees our recent 2021 Annual Report on Form 10-K. completed this education. Employees and contractors also complete annual awareness Industry-Leading Ethical Business Standards education on the Health Insurance Portability and Accountabili- We are a founding member of the Healthcare Group Purchasing ty Act (HIPAA) and on how to properly obtain, use, share, Industry Initiative (HGPII), a voluntary association dedicated to maintain and transfer protected data. During CY2020, 100% ethical conduct and business practices of Group Purchasing of employees completed this education. Organizations. HGPII is based on six core purposes, including As part of our annual compliance education, employees also the creation of and adherence to a written code of business complete several online education courses to meet regulatory conduct that establishes high ethical values, quality healthcare, requirements, including programs to satisfy the annual fraud, cost-effectiveness, an open and competitive purchasing waste and abuse education requirements per the Code of process, sound business practices and public accountability. Federal Regulations (CFR) and sub-regulatory guidance for For a complete list of our professional associations, please Medicare Parts C and D plan sponsors. During CY2020, 100% see page 8 of this report. of employees completed this education. For the 14th consecutive year, Premier was named as one Our directors annually attest to their compliance with the of the World’s Most Ethical Companies by the Ethisphere® Code of Conduct, the Board Code of Ethics, the Board Conflict Institute, a global leader in defining and advancing the stan-of Interest Policy and Disclosure Statement and the Group dards of ethical business practices. We were selected for this Purchasing Code of Conduct (GPO Code). All sourcing commit- honor from among tens of thousands of companies around tee and advisory subcommittee members receive education the world in recognition of our continuing to raise the bar on annually on our GPO Code, Confidentiality Policy, Conflict of ethical leadership and corporate behavior. Interest Policy and Insider Trading Policy. During CY2020, 100% of directors, committee and subcommittee members completed this education and related acknowledgments. While addressing the challenges of 2020, Premier continues to cultivate trust and lead its employees and the communities it serves with purpose and a sense of corporate citizenship. Table of Contents CEO Letter Making a Awards and About This Governance People and Social Supply Chain Environmental Frameworks Premier Impact Associations Report Culture Responsibility Management Management and Standards 15
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