Code of Conduct and Ethics Policy

I. Purpose

  • The Code covers a wide range of business practices and procedures. It does not cover every issue that may arise, but it sets out basic principles to guide associates of Passport Advantage (HMO-SNP). Associates must conduct themselves accordingly and seek to avoid even the appearance of improper behavior.

II. Principles

  • Equal Opportunity
  • Compliance With Legal and Contractual Obligations
  • Transparency
  • Confidentiality
  • Partnership-based Cooperation

III. Policies

  • Passport Advantage’s success is built on its mission, vision and values. They serve as the basis for Passport Advantage’s business practices and the rules for associate behavior.  Therefore, associates are required to act in a manner consistent with the mission, vision and values.
  • Conflict of Interest
  • Gifts and Kickbacks
  • Non-Retaliation

IV. Ethical Responsibilities

  • Be truthful
  • Cooperate fully

V. Business Practices

  • Confidentiality of Information
  • Maintenance and Accuracy of Records
  • Cooperating with the Government
  • Solicitation
  • Representation of Passport
  • Personal Use of Passport Resources
  • Political Activity
  • Post-Employment Recruiting and Confidentiality

VI. Reporting

Associates may contact Passport Advantage if they want to report suspected or actual occurrence(s) of illegal, unethical or inappropriate activities.  The report can be made by:

  • contacting their manager, another manager, a director, or Vice President;
  • contacting the Chief Compliance Officer or VP of Human Resources by telephone or by e-mail;
  • calling Passport Advantage’s Hotline at 1-855-512-8500; or sending an email to

Last Modified: January 23, 2020