Compliance & Ethics

At Seamen’s Society for Children and Families, we hold ourselves to the highest ethical, legal, and professional standards. Our Compliance and Ethics Program encourages the identification, communication, and correction of compliance issues to ensure that all our activities are ethical and legally compliant.

Our commitment affects everything we do:

• it means we promote responsible, honest conduct;
• our business transactions and program operations are transparent; and,
• we strive to assure a culture of compliance so that we not only respect the laws and regulations of the government agencies that fund our work, but work every day to offer the very highest standards of care to the children and families we support.

Our Professional Code of Conduct

Our Compliance and Ethics Program incorporates professional conduct and standards which provides all employees with guidelines to demonstrate honest behaviors. We understand that such code may not be a catch-all, and employees may be confronted with difficult decisions, however, we expect all employees to be prepared to exercise good judgment and common sense.

Safe Workplace

Seamen’s Society is committed to providing a safe working environment free of intimidation, threatening speech or behavior, threats of harm, or violence, whether engaged in by another employee or a third party, such as vendors or volunteers. Seamen’s Society strictly prohibits retaliation in any form against applicants or employees who in good faith make complaints or raise issues concerning discrimination, harassment, or any other violation of the law or the professional code. Anyone who engages in retaliation will be disciplined up to and including termination.

Our Compliance and Ethics Program is driven by the seven elements Written Standards of Conduct, Policies, and Procedures. The Compliance and Ethics Program and Employee Handbook set clear expectations about how we should act toward the children and families we support, the vendors with whom we do business, the government entities that regulate and fund us, and even how we interact with our colleagues. We also have specific policies and procedures addressing: 

• Conflict of Interest 
• Compliance Responsibility Reporting 
• False Claims and Whistleblower 
• Incident Reporting
• Documentation of Services Rendered
• Billing for Services including processes to detect, record, and correct errors 
• Gift Acceptance 
• Consultant and Vendor Agreements 

The Compliance Officer and Compliance Committee 

The agency’s Compliance Officer coordinates and monitors compliance activities across the agency, with the help of a committee made up of employees from across the agency. The Compliance Committee meets to monitor compliance activities and evaluate the effectiveness of the Compliance and Ethics Program.

Education and Training

All employees receive Compliance and Ethics Program training when they are first hired and every year after that. Members of the Board of Directors also attend annual training.  

Internal Lines of Communication

Seamen’s Society is committed to fostering open communications at all levels within the organization. If you are an employee, vendor, or contractor who thinks there may be an issue with abuse, fraud, or waste, you are urged to report the situation to a member of Seamen’s Society’s Management Staff, or to: 

• Karen DeGraaf, Compliance Officer, 718-447-7740 ext. 4235 
• Seamen’s Society’s Compliance and Ethics Program Hotline, 718-447-7740 ext. 4444 

For an employee, reporting misconduct is an obligation set out in our Code of Conduct, whenever you have reason to believe it is taking place. No attempt will be made to identify an individual who requests anonymity, and even if you choose to use your name, your name will not be revealed unless required by law or usual circumstances. 

No person who makes a report in good faith has to worry about retaliation. The agency is committed to responding promptly and appropriately. 

Enforcement and Discipline 

Every employee is expected to uphold the agency’s high ethical standards and any violation of the Code of Conduct is subject to disciplinary action, which could result in sanctions, from warnings to suspension or termination. 

Monitoring and Auditing 

The agency works hard to prioritize risks, and monitor them, accordingly, taking into account changes in regulatory requirements, operations or business practices. 

Responding to Compliance Issues 

As part of its Compliance and Ethics Program, Seamen’s Society will ensure that all reports of suspected waste, fraud or abuse or violations of the agency Code of Conduct will be immediately and objectively investigated and resolved promptly. 

Protection from Retaliation 

To ensure that no one who makes a good faith report of a problem is punished in any way at all, the agency is committed to disciplining any employee who discharges, suspends, threatens, or otherwise discriminates against an employee who, in good faith, initiates or assists in reporting a suspected violation of our Code of Ethics. 

HIPAA 

Protecting confidential health information is essential to an agency like ours and the Health Information Portability and Accountability Act (HIPAA) is the Federal law that secures protected health information (PHI). We have developed policies and procedures that ensure our compliance with HIPAA regulations.