Fulton Drugs Inc
NCPDP: 3351498
1548 Fulton St
Brooklyn, NY 11216
EFFECTIVE July 12, 2023
Who Must Follow This Code?
This Code of Conduct, Business Ethics, and Conflict of Interest Policy (herein referred to as “Code”) is
applicable to Fulton Drugs Inc, its Owners, Officers, Agents, and All affected individuals, including but not
limited to Employees. The reputation, respect, and standing within the community served by Fulton Drugs
Inc results from our dedication to professional and business standards of the highest integrity.
Your Personal Pledge to Do the Right Thing
The Code represents a commitment to doing what is right. By working for Fulton Drugs Inc, you are
agreeing to uphold this commitment; you understand the standards of the Code and will always follow
them. If you fail to follow these standards, you place Fulton Drugs Inc, your fellow coworkers, and yourself
at Risk. This Code of Conduct is more than just a description of our standards; it is the centerpiece of our
compliance and integrity program and assures that all of us conduct business with the highest standards of integrity.
Honest and Ethical Conduct
Fulton Drugs Inc is committed to honest and ethical conduct, including the ethical handling of actual or
apparent conflicts of interest between personal and professional relationships. We recognize that Fulton
Drugs Inc is harmed when the real or apparent private interest of an Owner, Officer, Agent or Affected
individuals, including but not limited to an Employee is in conflict with the interests of Fulton Drugs Inc.
This occurs, for example, when someone receives improper personal benefits as a result of their position
with Fulton Drugs Inc or has other duties, responsibilities, or obligations that run counter to their duty to
Fulton Drugs Inc.
Conflicts of Interest
A “conflict of interest” arises when a personal, social, financial or political activity has the potential of
interfering with your loyalty and objectivity to Fulton Drugs Inc. Actual conflicts must be avoided; even the appearance of a conflict of interest can be harmful and should be avoided. Our Policy & Procedure Manual describes common ways that conflicts of interest can arise. If affected individuals, including but not limited to employees are unsure if a “conflict of interest” may exist, ask Fulton Drugs Inc’s management, for permission prior to — rather than hoping for forgiveness after the fact.
Fulton Drugs Inc Opportunities
All affected individuals, including but not limited to employees, officers and directors, may not use Fulton
Drugs Inc or Fulton Drugs Inc’s property or proprietary information, or their positions with Fulton Drugs
Inc, for personal gain. You should never take or claim as your own, business opportunities that you learn
about through your work for Fulton Drugs Inc. Also, never engage in any business activities that compete
with or compromise Fulton Drugs Inc.
Receiving Gifts and Entertainment
Relationships with others must be based entirely on sound business decisions and fair dealing. Business
gifts and entertainment can build goodwill, but they can also make it harder to be objective about the
person providing them. In short, gifts and entertainment can create their own “conflicts of interest.” All
affected individuals including but not limited to employees of Fulton Drugs Inc must follow the written
procedures regarding acceptable and unacceptable gift giving and receiving.
Financial Integrity
Fulton Drugs Inc always strives to retain the trust of our affected individuals including but not limited to
employees and business associates. Any invoices, claims for payments, reports and documents that Fulton
Drugs Inc submits to any governmental agency or business associate shall always be full, fair, accurate,
timely and understandable.
Accurate and Complete Books, Records and Accounting
Fulton Drugs Inc’s credibility is judged in many ways—and one very important way is the integrity of its
books, records and accounting. In addition to our own commitment to accurately report financial
performance, Fulton Drugs Inc is required by law to follow generally accepted accounting principles.
Every affected individuals including but not limited to employees of Fulton Drugs Inc must ensure that the reporting of business information, electronic, paper or otherwise, is accurate, complete and timely. This includes accurately booking costs, sales, timesheets, vouchers, bills, payroll and benefits records,
regulatory data and other essential Fulton Drugs Inc information.
In addition, all affected individuals, including but not limited to employees, must:
never deliberately make a false or misleading entry in a report or record.
never alter or destroy Fulton Drugs Inc records except as authorized by established policies and
procedures.
never sell, transfer or dispose of Fulton Drugs Inc assets or any Fulton Drugs Inc confidential
information without proper authorization and documentation.
cooperate with Fulton Drugs Inc’s Compliance Officer and any investigation by the Compliance
Officer.
contact the Fulton Drugs Inc Management or Fulton Drugs Inc’s Compliance Officer with any
questions about the proper recording of financial transactions.
never encourage, direct, facilitate or permit non-compliant, illegal, or unethical behavior.
If you have a concern about a legal or business conduct issue, you are obligated to report and raise the
issue with Fulton Drugs Inc’s management.
We All Must Follow the Code of Conduct and Government Laws and Regulations.
All affected individuals including but not limited to employees who perform work for Fulton Drugs Inc shall be held accountable for complying with applicable laws, government rules, regulations, including Medicare Part D and this Code. In addition, all affected individuals including but not limited to employees shall be committed to following Fulton Drugs Inc’s Fraud, Waste and Abuse Compliance Program to prevent, detect, report and correct fraud, waste and abuse to the maximum extent possible. Fulton Drugs Inc does not employ any person who has been excluded from participating in any government funded program. Fulton Drugs Inc runs a background search of both the Office of the Inspector General’s and General Service Administration’s Exclusion Lists to screen new hires prior to employment and all affected
individuals including but not limited to employees on a monthly basis.
Unauthorized Release of Confidential Information
Unauthorized release of confidential Fulton Drugs Inc information, including, but not limited to,
proprietary information, lists, contracts, financial information, or patient personal health information; shall
be considered a major violation of the Code.
Any Owner, Officer, Agent or affected individuals including but not limited to employee of Fulton Drugs Inc that releases confidential information without authorization may be terminated from employment.
Enforcement: Discipline Imposed for Violations
Violations of this Code are subject to discipline by Fulton Drugs Inc Management including oral and written warnings, reprimands, suspensions, terminations and financial penalties. The Compliance Officer and Management of Fulton Drugs Inc reserve the right to determine the appropriate discipline to fit the
circumstances. Violations shall be dealt with swiftly and illegal acts of violators may be reported to the
authorities as appropriate. Enforcement of the Code shall be prompt and consistent, applying appropriate
standards and processes as determined.
Annual Commitment
All affected individuals including but not limited to employees, will be required to renew their acceptance
of the Code annually.