Procurement Ethics & Compliance

We maintain the highest ethical and business standards in our dealings with suppliers. We use established guidelines for all our procurement activities. We maintain a strict code of conduct, with ethical behavior required of all procurement professionals.

Learn more about our Third Party Code of Business Conduct

Government Compliance

We are responsible for administering several different governmental contracts including but not necessarily limited to Medicare, the Federal Employees Health Benefits Program (FEP) and the Children's Health Insurance Program (CHIP).

To the extent that we operate under the auspices of these contracts, we have an affirmative responsibility to meet our contractual, regulatory and statutory requirements when acquiring goods and services to be used in the performance of our government contracts. These regulatory requirements include provisions within the Federal Acquisition Regulation (FAR) and various other statutes and regulations, federal and otherwise.

These requirements include but are not necessarily limited to the following:

  • Prior Notification/Approval — All procurements allocating $25,000 or more to the federal government that are defined as subcontracts must have prior notification or prior approval. These requirements can potentially add an additional 20 to 60 days to the processing of purchase orders and contracts and must be performed prior to awarding any commitments to a supplier. It is therefore prudent that all commodity and procurement teams address this issue in the beginning stages of their commodity or procurement planning and solicitations.
  • Flow Down Clauses — Procurements that allocate more than $25,000 or more to the federal government that are defined as subcontracts must have government-defined contract clauses included. These flow down clauses need to be incorporated into either the purchase order or contract.
  • Maximize Competition — Sealed bidding and competitive negotiations are the two main solicitation methods that are approved and promoted by the Federal Acquisition Regulations. The competitive process may begin at purchases exceeding $2,500 and the process used is determined by complexity, dollar threshold, etc. For high dollar and complex procurement, the vehicle used will be either a Request for Proposal (RFP) or Request for Quotation (RFQ).
  • Supplier Certification — We may not allow suppliers to participate in any procurement activity if they have been debarred, suspended or otherwise excluded in such activity by the government. Therefore, we must verify the debarment status of all suppliers that will receive orders with government-allocated dollars prior to the placing of such orders.
  • Documentation Requirements — The government determines compliance to their requirements based upon the documentation that supports the activity. Therefore, when audits are performed, documentation must be available that provides proof of our adherence to these regulations.

Further details can be obtained by contacting corporate procurement at