Preventing Falls in Hospitals: a Toolkit for Improving Quality of Care

Total Page:16

File Type:pdf, Size:1020Kb

Preventing Falls in Hospitals: a Toolkit for Improving Quality of Care Preventing Falls in Hospitals A Toolkit for Improving Quality of Care The information in this toolkit is intended to assist service providers and hospitals in developing falls prevention protocols. This toolkit is intended as a reference and not as a substitute for professional judgment. The opinions expressed in this document are those of the authors and do not necessarily reflect the views of AHRQ. No statement in this toolkit should be construed as an official position of AHRQ or the U.S. Department of Health and Human Services. In addition, AHRQ or U.S. Department of Health and Human Services endorsement of any derivative product may not be stated or implied. Preventing Falls in Hospitals A Toolkit for Improving Quality of Care Prepared for: Agency for Healthcare Research and Quality 540 Gaither Road Rockville, MD 20850 www.ahrq.gov Prepared by: RAND Corporation Boston University School of Public Health ECRI Institute Contract No. HHSA290201000017I TO #1 AHRQ Publication No. 13-0015-EF January 2013 Authors RAND Corporation David A. Ganz, M.D., Ph.D., VA Greater Los Angeles Healthcare System, University of California at Los Angeles, and RAND Corporation Christina Huang, M.P.H., RAND Corporation Debra Saliba, M.D., M.P.H., VA Greater Los Angeles Healthcare System, UCLA/JH Borun Center for Gerontological Research, and RAND Corporation Victoria Shier, M.P.A., RAND Corporation Boston University School of Public Health Dan Berlowitz, M.D., M.P.H., Bedford VA Hospital and Boston University School of Public Health Carol VanDeusen Lukas, Ed.D., VA Boston Healthcare System and Boston University School of Public Health ECRI Institute Kathryn Pelczarski, B.S. Karen Schoelles, M.D., S.M. Linda C. Wallace, M.S.N., B.S.N. Patricia Neumann, R.N., M.S. This document is in the public domain and may be used and reprinted without special permission. Citation of the source is appreciated. Suggested citation: Ganz DA, Huang C, Saliba D, et al. Preventing falls in hospitals: a toolkit for improving quality of care. (Prepared by RAND Corporation, Boston University School of Public Health, and ECRI Institute under Contract No. HHSA290201000017I TO #1.) Rockville, MD: Agency for Healthcare Research and Quality; January 2013. AHRQ Publication No. 13-0015-EF. ii Contents Roadmap ..........................................................................................................................................v Acknowledgments.......................................................................................................................... ix Overview ..........................................................................................................................................1 The Problem of Falls ..................................................................................................................1 The Challenges of Fall Prevention .............................................................................................1 Toolkit Designed for Multiple Audiences .................................................................................2 Implementation Guide Organized To Direct Hospitals Through the Change Process ..............3 Sections of the Guide .................................................................................................................3 Adaptation of the Guide to Your Organization..........................................................................3 Improvement as Puzzle Pieces ...................................................................................................4 Icons .................................................................................................................................................5 1. Are you ready for this change? ....................................................................................................6 1.1. Do organizational members understand why change is needed? ........................................6 1.2. Is there urgency to change? .................................................................................................8 1.3. Does senior administrative leadership support this program? ............................................9 1.4. Who will take ownership of this effort? ...........................................................................11 1.5. What kinds of resources are needed? ................................................................................12 1.6. What if you are not ready for full-scale change? ..............................................................12 1.7. Checklist for assessing readiness for change ....................................................................13 2. How will you manage change? ..................................................................................................14 2.1. How can you set up the Implementation Team for success? ............................................15 2.2. What needs to change and how do you need to redesign it? ............................................19 2.3. How should goals and plans for change be developed? ...................................................25 2.4. Checklist for managing change .........................................................................................26 3. Which fall prevention practices do you want to use? ................................................................27 3.1. Which fall prevention practices should you use? .............................................................28 3.2. What are universal fall precautions and how should they be implemented? ....................30 3.3. What is a standardized assessment of risk factors for falls, and how should this assessment be conducted? ............................................................................................34 3.4. How should identified risk factors be used for fall prevention care planning? ................38 3.5. How should you assess and manage patients after a fall? ................................................46 3.6. How can your hospital incorporate these practices into a fall prevention program? ........49 3.7. What additional resources are available to identify best practices for fall prevention? ...51 3.8. Checklist for best practices ...............................................................................................51 4. How do you implement the fall prevention program in your organization? .............................52 4.1. What roles and responsibilities will staff have in preventing falls? .................................53 4.2. What fall prevention practices go beyond the unit?..........................................................59 4.3. How do you put the new practices into operation? ...........................................................60 4.4. Checklist for implementing best practices ........................................................................67 5. How do you measure fall rates and fall prevention practices? ..................................................68 5.1. How do you measure fall and fall-related injury rates? ....................................................69 5.2. How do you measure fall prevention practices? ...............................................................77 5.3. Checklist for measuring progress......................................................................................80 iii 6. How do you sustain an effective fall prevention program? .......................................................81 6.1. Who will be responsible for sustaining active fall prevention efforts on an ongoing basis? .........................................................................................................82 6.2. How will you continue to monitor fall rates and fall prevention care processes? ............82 6.3. What types of ongoing organizational support do you need to keep the new practices in place? ........................................................................................................83 6.4. How can you reinforce the desired results? ......................................................................84 6.5. Summary ...........................................................................................................................87 7. Tools and Resources ..................................................................................................................89 Appendix: Bibliography of Studies Implementing Fall Prevention Practices .............................185 iv Roadmap Who Should Use The Section Action Steps Tool That Supports Action Tool Overview Enlist support of senior leaders Tool ØA, Introduction and Overview for Senior manager Stakeholders Section 1 Are you ready for this change? 1.1 Assess the culture of safety in your Tool 1A, Hospital Survey on Patient Safety Culture All interdisciplinary hospital team members 1.2 Evaluate current organizational Tool 1B, Stakeholder Analysis Implementation Team attention to falls leader 1.3 Assess and develop leadership Tool 1C, Leadership Support Assessment Implementation Team support for the fall prevention leader program Tool 1D, Business Case Form 1.5 Identify resources that are available Tool 1E, Resource Needs Assessment Implementation Team and resources that are needed leader 1.7 Assess your progress on completing Tool 1F, Organizational Readiness Checklist Implementation Team readiness for change activities leader Section 2 How will you manage change? 2.1 Identify your Implementation Team Tool 2A, Interdisciplinary
Recommended publications
  • A Thesis Entitled Quality of Life of People Who Stutter by Emily
    A Thesis entitled Quality of Life of People who Stutter by Emily Figliomeni Submitted to the Graduate Faculty as partial fulfillment of the requirements for the Master of Arts Degree in Speech Language Pathology _________________________________________ Dr. Rodney Gabel, Ph.D., CCC-SLP, BCS-F, Committee Chair _________________________________________ Dr. Stephanie Hughes, Ph.D., CCC-SLP, Committee Member _________________________________________ Mrs. Jennifer Glassman, M.A. CCC-SLP, Committee Member _________________________________________ Dr. Patricia R. Komuniecki, Ph.D., Dean College of Graduate Studies The University of Toledo May 2015 Copyright 2015, Emily Figliomeni This document is copyrighted material. Under copyright law, no parts of this document may be reproduced without the expressed permission of the author. An Abstract of Quality of Life of People who Stutter by Emily Figliomeni Submitted to the Graduate Faculty as partial fulfillment of the requirements for the Master of Arts Degree in Speech Language Pathology The University of Toledo May 2015 Stuttering is a communication disorder that can impact a person’s life. The purpose of this study was to qualitatively explore the impact of stuttering on quality of life (QOL), and the differences between the beliefs of people who stutter (PWS) and the speech-language pathologist (SLP) regarding this issue. Individual experiences were obtained through the process of open-ended interviews with six PWS, and six SLPs who work with PWS. Major recurring themes included: 1) restriction, 2) identity, 3) positivity, 4) control, and 5) therapy impact. Similar beliefs were shared among individuals in both groups of participants, and were reflected in additional minor themes including therapy impact on QOL, physical impact, empowerment, acceptance, authenticity, and restriction regarding occupation and personal relationships.
    [Show full text]
  • Sound Ethics in Health Care in Depth: Speak Up! Listen Up! May 14, 2018
    Sound Ethics in Health Care In Depth: Speak Up! Listen Up! May 14, 2018 Dr. John Billig: Hello, and thank you for joining today's IntegratedEthics Improvement Forum Call. I'm John Billig, Chief of IntegratedEthics. As you probably know, today marks the beginning of National Compliance and Ethics Week in VA. This year's theme is Speak up! Listen up! And today's call will celebrate that theme. It promises to be an interesting and enlightening discussion. And now to kick things off, it's my great pleasure today to introduce our first speaker, Dr. Gerard Cox. Dr. Cox is Acting Deputy Under Secretary for Health for Organizational Excellence while continuing to serve as Assistant Deputy Under Secretary for Health for Integrity. Prior to his current role, he served as Assistant Deputy Under Secretary for Health for Policy and Services, Interim Medical Inspector, and Assistant Deputy Under Secretary for Health for Integrity. Before joining VA in 2014, Dr. Cox spent more than 30 years in military medicine. As a U.S. Navy medical officer, he served in a series of hospital leadership roles with increasingly complex management responsibilities, including service chief, service line leader, chief operating officer, and chief executive officer. He also held executive positions with the Navy Surgeon General, the commandant of the Marine Corps, the commander of U.S. Navy forces in the Middle East, and the Naval Inspector General. In addition, Dr. Cox served as a White House physician for Presidents William J. Clinton and George W. Bush. Dr. Cox, thank you for joining us today.
    [Show full text]
  • Department of Health and Human Services
    Vol. 78 Wednesday, No. 39 February 27, 2013 Part II Department of Health and Human Services 45 CFR Parts 144, 147, 150, et al. Patient Protection and Affordable Care Act; Health Insurance Market Rules; Rate Review; Final Rule VerDate Mar<15>2010 15:19 Feb 26, 2013 Jkt 229001 PO 00000 Frm 00001 Fmt 4717 Sfmt 4717 E:\FR\FM\27FER2.SGM 27FER2 erowe on DSK2VPTVN1PROD with RULES_2 13406 Federal Register / Vol. 78, No. 39 / Wednesday, February 27, 2013 / Rules and Regulations DEPARTMENT OF HEALTH AND A. Part 144—Requirements Relating to Federal Register proposed rule entitled HUMAN SERVICES Health Insurance Coverage ‘‘Patient Protection and Affordable Care 1. Subpart A—General Provisions Act; Health Insurance Market Rules; 45 CFR Parts 144, 147, 150, 154 and B. Part 147—Health Insurance Reform Rate Review’’ (77 FR 70584). These 156 Requirements for the Group and Individual Health Insurance Markets standards apply to health insurance [CMS–9972–F] 1. Fair Health Insurance Premiums issuers offering non-grandfathered 2. State Reporting health insurance coverage both inside RIN 0938–AR40 3. Guaranteed Availability of Coverage and outside of the new competitive 4. Guaranteed Renewability of Coverage marketplaces called Affordable Patient Protection and Affordable Care C. Part 150—CMS Enforcement in Group Insurance Exchanges, or ‘‘Exchanges.’’ Act; Health Insurance Market Rules; and Individual Insurance Markets This final rule: (1) Provides that Rate Review D. Part 154—Health Insurance Issuer Rate health insurance issuers may vary the Increases: Disclosure and Review AGENCY: Department of Health and premium rate for health insurance Requirements coverage in the individual and small Human Services.
    [Show full text]
  • Checklist to Prepare Physician Offices for COVID-19
    Checklist to Prepare Physician Offices for COVID-19 ASSUMPTION: Transmission will be primarily through exposure to respiratory droplets and direct contact with patients and their contaminated environments. Universal Early Preparation within six feet of patients with suspected COVID-19 infection. (See approved respirators). Provide training ☐ Educate staff and patients about changes they for staff on respirators to ensure fit and appropriate can expect to be implemented in the office use. during an outbreak or pandemic, and about ways to prepare themselves and their families. • Ensure adherence to standard precautions, including airborne precautions and use of eye protection. Assume that every patient is potentially infected or COVID-19 Education colonized with a pathogen that could be transmitted in • Educate staff about coronavirus disease 2019 a health care setting. (COVID-19), and why it is important to contain the • Implement mechanisms and policies that promptly outbreak. alert key facility staff including infection control, health • Educate staff on facility policies and practices care epidemiology, facility leadership, occupational to minimize chance of exposure to respiratory health, clinical laboratory, and frontline staff about pathogens including SARS-CoV-2, the virus that known suspected COVID-19 patients (i.e. PUI). Keep causes COVID-19. updated lists of staff and patients to identify those at risk in the event of an exposure. • Train and educate staff with job-or task-specific information on preventing transmission of infectious • Staff should follow the CDC guidelines collecting, agents, including refresher training. handling and testing clinical specimens from (PUIs for COVID-19. • Educate staff about COVID-19 evaluation and treatment. • Prepare for office staff illness, absences, and/or quarantine.
    [Show full text]
  • Code of Conduct: Our Principles of Ethics & Integrity
    CODE OF CONDUCT Our Principles of Ethics & Integrity UnitedHealth Group Code of Conduct: Our Principles of Ethics & Integrity 4 Violations of the Code of Conduct and Policies 4 Waiver and Changes to the Code 4 Who to Contact with Questions or Concerns 5 Integrity 6 Act with Integrity 7 Integrity of Books and Records 7 Integrity Challenges 8 Associated Policies 9 Accountability 10 Be Accountable 11 Accountability Challenges 12 Associated Policies 13 Fair Competition and Fair Dealing 14 Comply with Fair Competition Laws and Company Policies 15 Challenges to Competing Fairly 16 Associated Policies 17 Privacy and Information Security 18 Protect Personal Information 19 Protect Privacy, Ensure Security 19 Privacy and Information Security Challenges 20 Associated Policies 21 Our Assets and the Environment 22 Be a Steward of our Assets and the Environment 23 Stewardship Challenges 24 Associated Policies 25 Government Interactions 26 Ensure Appropriate Interactions with Government Officials 28 Government Interaction Challenges 30 Associated Policies 31 Communications and Marketing 32 Communicate Effectively and Appropriately 33 Communication Challenges 34 Associated Policies 35 A Safe and Supportive Working Environment 36 Promote a Safe and Supportive Working Environment 37 Work Environment Challenges 38 Associated Policies 39 Code of Conduct UNITEDHEALTH GROUP AND INTEGRITY The people of UnitedHealth Group and its our work day-to-day is important to fulfilling subsidiaries around the world (“UnitedHealth our mission to help people live healthier lives Group” or “the Company”) share five and to help make the health system work better values that best describe how we aspire to for everyone. Health care is among the most conduct ourselves and our business: integrity, personal, intimate aspects of a person’s life, compassion, relationships, innovation, and and each individual must be able to trust our performance.
    [Show full text]
  • Advice to Those Who Stutter Who Those to Advice SECOND EDITION
    advice to those who stutter SECOND EDITION advice to those who stutter THE STUTTERING FOUNDATION® A Nonprofit Organization Since 1947—Helping Those Who Stutter 3100 Walnut Grove Road, Suite 603 P.O. Box 11749 • Memphis, TN 38111-0749 800-992-9392 901-452-7343 www.stutteringhelp.org Second Edition www.tartamudez.org SFA Publication SFA No. 0009 ISBN 0-933388-39-X Expert help from THE 28 therapists who STUTTERING stutter themselves FOUNDATION® ISBN 0-933388-39-X PUBLICATION NO. 0009 9 7 8 0 9 3 3 3 8 8 3 9 0 Myths about stuttering Winston Churchill John Stossel Marilyn Monroe James Earl Jones Myth: People who stutter are not smart. Did you know... Reality: There is no link whatsoever between stuttering and intelligence. Ⅲ Over three million Americans stutter. Stuttering affects three to four times as many males as females. Myth: Nervousness causes stuttering. Ⅲ Ⅲ Approximately 5% of all children go through a period of stuttering that lasts six months or Reality: Nervousness does not cause stuttering. Nor should we assume that more. Three-quarters of those will recover by late childhood, leaving about 1% with a long- people who stutter are prone to be nervous, fearful, anxious, or shy. term problem. They have the same full range of personality traits as those who do not stutter. Ⅲ Exciting new research in the areas of genetics, neurophysiology, child development, and family dynamics is shedding light on the possible causes of stuttering. As a result, we have made Myth: Stuttering can be “caught” through imitation or by hearing another tremendous progress in the prevention of stuttering in young children.
    [Show full text]
  • 2016 Health Care Heroes Lifetime Achievement Award Winner Michael Grossman, Maricopa Integrated Health System
    AUGUST 26, 2016 2 0 1 6 Honoring 26 dynamic health care professionals who are making patient’s lives better through their support and dedication PREMIER SPONSOR 28 PHOENIX BUSINESS JOURNAL AUGUST 26, 2016 29 HEALTH CARE HEROES he Phoenix Business Journal’s 15th annual Health Care Heroes awards honors those Arizona physicians, nurses, emergency responders and T volunteers who try to keep us all just a little bit healthier. A panel of judges, which included past award winners, selected this year’s honorees, who serve the community from the front office and behind the scenes in eight categories. A Lifetime Achievement award winner also was chosen. All of this year’s honorees were recognized at a special awards event held Aug. 25. 2016 Health Care Heroes Lifetime Achievement Award Winner Michael Grossman, Maricopa Integrated Health System ...............................................30 Lifetime Achievement Finalists Lesley Hunt, Orchard Medical Consuting ....................................................................................32 David Jacofsky, The CORE Institute ................................................................................................32 Innovator Award Winner Dr. Angela DeRosa, DeRosa Medical ........................................................................................... 33 Innovator Finalists Alexander Green, ASU Biodesign Institute ................................................................................ 34 Marc Lato, Dignity Health-St. Joseph’s Hospital and Medical Center........................35
    [Show full text]
  • Apr 16 Dinner Ltr021805
    ThyCa: Thyroid Cancer Survivorsʼ Association, Inc.SM An all-volunteer non-profit 501 (c)(3) organization of thyroid cancer survivors, family members, and health professionals, dedicated to support, communication, and education for thyroid cancer survivors, their families, and friends P.O. Box 1545, New York, NY 10159-1545 www.thyca.org Toll Free 1-877-588-7904 [email protected] Raise the Stakes for Thyroid Cancer Research! Join us for our Dinner/Play-Money "Casino Night," April 16, 2005, in Baltimore! Dear Friends, We thank you for your dedication to the well-being of thyroid cancer patients, and invite you to join us at our Dinner and "Casino Night" Fundraiser, with “play money” games (for fun, not for cash). This benefit evening is sponsored by ThyCa: Thyroid Cancer Survivorsʼ Association in cooperation with Light of Life Foundation and the American Thyroid Association. It's all for a good cause – thyroid cancer research. This special event starts at 7 p.m. on Saturday, April 16, 2005, at the Baltimore Waterfront Marriott Hotel, 700 Aliceanna Street, Baltimore, Maryland. Attire is casual. The hotel is also hosting ATA's Frontiers in Thyroid Cancer Meeting. The Dinner/Casino Night follows ThyCa's free one-day educational workshop on April 16 — ThyCaʼs 4th Annual Thyroid Cancer Survivorsʼ Mid-Atlantic Workshop. Tickets for the Dinner/Casino Night Fundraiser are payable by credit card or check to ThyCa. Your generosity beyond the dinner ticket cost is tax-deductible. Donations plus net proceeds from the benefit support thyroid cancer research. You are invited to attend, sponsor a ticket or a dinner table for others, sponsor a games table, or help us with a donation.
    [Show full text]
  • Commission on Ending Childhood Obesity
    REPORT OF THE COMMISSION ON ENDING CHILDHOOD OBESITY REPORT OF THE COMMISSION ON ENDING CHILDHOOD OBESITY WHO Library Cataloguing-in-Publication Data Report of the commission on ending childhood obesity. 1.Pediatric Obesity – prevention and control. 2.Child. 3.Feeding Behavior. 4.Food Habits. 5.Exercise. 6.Diet. 7.Health Promotion. 8.National Health Programs. I.World Health Organization. ISBN 978 92 4 151006 6 (NLM classification: WS 130) © World Health Organization 2016 All rights reserved. Publications of the World Health Organization are available on the WHO website (www.who.int) or can be purchased from WHO Press, World Health Organization, 20 Avenue Appia, 1211 Geneva 27, Switzerland (tel.: +41 22 791 3264; fax: +41 22 791 4857; e-mail: [email protected]). Requests for permission to reproduce or translate WHO publications –whether for sale or for non-commercial distribution– should be addressed to WHO Press through the WHO website (www.who.int/about/licensing/copyright_form/en/index.html). The designations employed and the presentation of the material in this publication do not imply the expression of any opinion whatsoever on the part of the World Health Organization concerning the legal status of any country, territory, city or area or of its authorities, or concerning the delimitation of its frontiers or boundaries. Dotted and dashed lines on maps represent approximate border lines for which there may not yet be full agreement. The mention of specific companies or of certain manufacturers’ products does not imply that they are endorsed or recommended by the World Health Organization in preference to others of a similar nature that are not mentioned.
    [Show full text]
  • Providing Performance Feedback to Individual Physicians: Current Practice and Emerging Lessons
    WORKING P A P E R Providing Performance Feedback to Individual Physicians: Current Practice and Emerging Lessons Final Report STEPHANIE S. TELEKI, REBECCA SHAW, CHERYL L. DAMBERG, ELIZABETH A. MCGLYNN WR-381-CHCF July 2006 This product is part of the RAND Health working paper series. RAND working papers are intended to share researchers’ latest findings and to solicit additional peer review. This paper has been peer reviewed but not edited. Unless otherwise indicated, working papers can be quoted and cited without permission of the author, provided the source is clearly referred to as a working paper. RAND’s publications do not necessarily reflect the opinions of its research clients and sponsors. is a registered trademark. Providing Performance Feedback to Individual Physicians TABLE OF CONTENTS EXECUTIVE SUMMARY ....................................................................................................... v I. INTRODUCTION.......................................................................................................... 1 II. STUDY METHODS ....................................................................................................... 2 A. Key Informant Interviews .................................................................................... 2 B. Literature Scan ....................................................................................................... 2 C. Environmental Scan .............................................................................................. 3 III. FINDINGS......................................................................................................................
    [Show full text]
  • Health Care at the Crossroads: Emergency Preparedness Systems
    HealthHealth CareCare atat thethe CrossroadsCrossroads Strategies for Creating and Sustaining Community-wide Emergency Preparedness Systems Joint Commission on Accreditation of Healthcare Organizations © Copyright 2003 by the Joint Commission on Accreditation of Healthcare Organizations. All rights reserved. No part of this book may be reproduced in any form or by any means without written permission from the publisher. Request for permission to reprint: 630-792-5631. Health Care at the Crossroads Strategies for Creating and Sustaining Community-wide Emergency Preparedness Systems Joint Commission on Accreditation of Healthcare Organizations Joint Commission Public Policy Initiative This white paper is the second work product of the Joint Commission’s new Public Policy Initiative. Launched in 2001, this initiative seeks to address broad issues that have the potential to seriously undermine the provision of safe, high-quality health care and, indeed, the health of the American people. These are issues which demand the attention and engagement of multiple publics if successful resolution is to be achieved. For each of the identified public policy issues, the Joint Commission already has state-of-the-art standards in place. However, simple application of these standards, and other unidi- mensional efforts,will leave this country far short of its health care goals and objectives. Thus, this paper does not describe new Joint Commission requirements for health care organizations, nor even suggest that new requirements will be forthcoming in the future. Rather, the Joint Commission has devised a public policy action plan that involves the gathering of information and multiple perspectives on the issue;formulation of comprehensive solutions; and assignment of accountabilities for these solutions.
    [Show full text]
  • Code of Ethics Business Conduct a Message from Our President
    CODE OF ETHICS BUSINESS CONDUCT A MESSAGE FROM OUR PRESIDENT Dear Team Member, At Regional One Health, our mission, values and commitment to the Memphis community enables us to deliver quality health care services to our patients. We strive to provide a caring environment at our facilities, and maintain a positive and professional culture for our employees and business partners. We are committed to delivering premier services and ensuring our work is done in an ethical and legal manner. We understand that laws and regulations related to the health care industry are often complex. The Regional One Health Code of Ethics & Business Conduct was developed to be your guide to better understand how we conduct business, to emphasize our commitment to ethical behavior and to act as a resource in making sound decisions. It is expected that you will use this document and the underlying principles as you go about your daily tasks and work together to drive Regional One Health forward. If you have questions regarding any section of this Code of Ethics & Business Conduct or encounter any situation which you believe violates its provisions, it is your duty to immediately consult with your manager, any member of executive leadership, Corporate Compliance or Human Resources. You may also call the Compliance Hotline to report concerns anonymously. You have our personal assurance there will be no retribution for asking questions, raising concerns, or for reporting possible improper conduct related to this Code of Ethics & Business Conduct. This Code of Ethics & Business Conduct is not a substitute for our own internal sense of fairness, honesty, and integrity.
    [Show full text]