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TRANSCRIPT
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ation, includipurposes beany and not credentials (ine.
Ethics L
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ms such as inny other tang
e Company ntheft or othereputation.
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reserves the rection of thei
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ders & t
ventory, officgible propertame, logo, trr misuse is th
e Compa”
right to requiir person, veht to monitor cations are th
th
e gue.
S-2040 Ethics
the Com
ce and store ety that CVS Hade secrets, se responsibil
any name
ire any colleahicle, uniformcommunicat
he sole prope
C
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mpany, c
equipment, vealth owns, rstrategies anlity of every c
e, logo, tr
ague, while om, locker, paction tools, incerty of CVS He
CVS Health Co
continued
vehicles, supprents or leased customer i
colleague bec
ade secre
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ode of Conduc
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o Uo So Mo A
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cipal operatiners and empl-public informessing mater
erial to the Cong a permittesaction occures by Compa
closure of
eagues and Dpany to any
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urred, he or sh
ionship
ng Laws
ainst federal lon about thatision to buy oation that is nny trade of C
may be regar
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mation due torial non-publompany. Theed trading wirs. These restany Personne
f Non-Pub
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he must imm
with Sh
aw to trade st company. Inor sell the stonot available CVS Health sto
rded as mate
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ve or negativebe considere
k trading polditional restricicers of CVS Hes who are reCompany or
o their knowlic informatio
ese individuandow and mtrictions are e
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blic Mater
not permittedtity outside tposted on thlth believes tediately noti
Ethics L
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stocks or othenformation is
ock. Nor may to the publicock, including
erial may inclu
s of future earoposed merge
management; mation that d
e informationed material no
icy applies toctions regardHealth, as weegularly in por its principal edge of the C
on that are dels are conside
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d to make anthe Companyhe Company’s
hat a disclosufy the Genera
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ders & t
er securities os considered we “tip”, or p
c. We will alwg stock optio
ude, but is no
rnings or lossers, acquisitioor
departs from
n may be maton-public inf
o all Directorsding Compan
ll as designatossession of m
operating suCompany’s fi
esignated by ered Key Pers
y trade with ththe Company
mation
ny disclosure y unless the ds Policy and Pure of material Counsel.
S-2040 Ethics
the Com
of a public comaterial if it
pass informatways review aon exercises a
ot limited to:
ses; ons or financ
m what the ma
terial. If you formation, yo
s, officers, any stock tradinted officers a
material non-ubsidiaries whnancial repothe Companysons. Key Pehe Office of ty’s Statement
of material, ndisclosure comProcedure Poial non-public
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s.BusinessCond
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ompany if wewould likely tion on to othnd abide by t
and purchase
cing transacti
arket would e
have any conou should con
d employeesng apply to: (nd employee
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the Corporatet of Company
non-public inmplies with tortal. If a collec information
CVS Health Co
continued
e have materiaffect the stohers to trade,the stock trad
es or sales of C
ons;
expect.
ncerns as to wntact our Gen
s of CVS Healt(1) members es of the Commation; (2) deuently possess; and (3) other role in projenly trade CVSe Secretary by Policy on Se
formation abhe Companyeague or men about the C
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al, non-ock price or , if the “tip” isding policy CVS Health
whether neral Counse
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mpany or its esignated ss material er employeesects that are S Health stockefore the ecurities
bout the y’s Regulationmber of the
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CVS HRecodirecsuchnevelitigarecor
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eagues and mmunity, inclu
Company unlhibition includrations, proceness.
cords Rete
Health worksords Managemction and sup as pharmaci
er destroy recation is comprds according
ionship
Informat
members of thuding “broker
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ention and
s to ensure thment Programpport in propists and nursecords subject pleted, even ifg to our Corp
with Sh
ion from t
he Board of Drs” or any peren explicitly ang of informamer service o
d Manage
hat we handlem, where apperly managines, must folloto audit, pen
f they have reporate Record
Ethics L
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the Invest
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ders & t
tment Com
not permittepting to arrann advance by any issues relice issues or p
ain all Compaprovides coll
ds throughoutory and/or acgation or pennd of the reqent Program.
S-2040 Ethics
the Com
mmunity
ed to speak wge consultatour Investorating to our Cpositions/op
any records inleagues, cont
ut their life cyccreditation snding litigatioquired retenti.
C
s.BusinessCond
mpany, c
with membersions, regardin Relations DeCompany, incinion on any
n accordancetingent workcle. Records standards anon until the aion period. W
CVS Health Co
continued
s of the invesng any informepartment. Tcluding our pissues conce
e with our Corkers and supp
used by profnd requiremeaudit, investigWe must alwa
ode of Conduc
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tment mation aboutThis policies, erning our
rporate pliers with fessionals, nts. We gation or ays manage
ct
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eriences, skillsrences to wo
grity and resprs the way yo
n-Discrim
Health is comronment free
ence. Our concipation of aion, gender, gal orientationran status or icable laws a
elop and promifications.
should:
Never disbehavior threateni
Call the loimmediat
ionship
One Anoth
our greatest nd cultures, as and talents.
ork as a team pect. A good ou would like
ination
mmitted to me from discrimntinued succell our colleaggender identn, national orany other chnd regulation
mote based s
rupt the worthat is disresng or harassi
ocal police if yte threat of v
with Ea
her
strength. Weand have a va. We embractreating eachshow of resp
e to be treate
maintaining a mination, haraess depends
gues — regartity or expresrigin, disabilitaracteristic pns. We recrusolely on job-
rk environmepectful, intimng. you become iolence.
Ethics L
ach Oth
e come from ariety of
ce these h other with pect is treatind.
workplace assment andon the full dless of age, sion, race, coty, military or
protected by it, hire, train, -related
ent through midating,
the target of
Line 1-877-CVS
er
ng
olor, r
f an
E
S-2040 Ethics
Examples
Inapprop Unwelco
favors, suphysical cor physic
Displayinobscene drawings
Commenand otheor stereogender idorientatiostatus anpersonal
Threats oThreats, sthe work
Retaliatioacts of m
C
s.BusinessCond
s of Harass
priate physicame sexual ad
uggestive comcontact and a
cal conduct ong derogatory
pictures, carts. nts, jokes, insuer unwelcomeotypical baseddentity or expon, national o
nd any other pcharacteristi
or acts of violestalking, even
kplace, are all on for reporti
misconduct.
CVS Health Co
sment
al contact. dvances, requmments, inapany other un
of a sexual naty, vulgar, sugtoons, calend
ults, slurs, offe actions whid upon age, rpression, raceorigin, disabiprotected catic. ence and intin suggestionconsidered vng or threate
ode of Conduc
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uests for sexuppropriate welcome verture.
ggestive or dars, posters
fensive languich are offensreligion, gende, color, sexulity, veteran tegory or
imidation. s of violence violent. behaening to repo
ct
6
ual
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or
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in vior.
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CVS Hhourlocalimpr
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all have a righ as personal
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ugs and Al
are committeexchange orpany, is strictwhen repres
gitimate busipermitted. Wair our ability
mbling
sistent with obling, raffles ng pools and
league Pr
VS Health, out protect the rmation of th
bor Practic
Health is comrs, compensa laws and reg
roperly emplo
ionship
afety
ht to work in ainjury, injury
afety of ourse
ollow facility sus equipmentork activities i
dispose of ther witness or s
lcohol
d to providinr purchase of tly prohibitedsenting the Ciness event.
We should nevto perform o
our commitmor other gam
d all other for
rivacy
ur work someconfidentialie people we
ces
mmitted to betion, human
gulations, incoys under ag
with Ea
a safe and heto colleague
elves, our coll
safety rules, rt and materianvolve medi
hem safely. suffer an acc
ng an alcoholdrugs or illeg
d. Likewise, uCompany is st
Prescription ver come to wour job or jeo
ment to compmes of chancerms of gambl
etimes requireity of this infoserve.
e in complianrights and w
cluding not kne workers. T
Ethics L
ach Oth
ealthy environes and the Coleagues and a
regulations, pals. cations or ot
ident, or see
-free and drugal substance
use, possessiotrictly prohibdrugs ordere
work under thopardize the s
lying with alle using Comping.
es access to cormation and
nce with all apworking condi
nowingly dohe Company
Line 1-877-CVS
er, contin
nment. Unsaompany or ot
anyone doin
procedures an
her substanc
unsafe cond
ug-free work es on Compaon, sale or exited, except w
ed by a physihe influence osafety of othe
federal and pany resource
colleague head hold it to th
pplicable lawitions. CVS Hing business
y also prohibi
S-2040 Ethics
nued
afe practices cher serious og business w
nd warnings,
ces that may b
itions, report
environmentany premises,change of alcwhen associacian, which dof alcohol, drers.
state laws, CVes or in Comp
alth care andhe same level
ws and regulaHealth will com
with a vendots the use of
C
s.BusinessCond
can lead to seoutcomes. Wewith us.
, particularly
be toxic if no
t the situation
t. The unaut, or at any timcohol on Comated with an ado not interferugs or any o
VS Health strpany facilitie
d/or other sen of protection
ations, includmply with allor or businessany forced o
CVS Health Co
erious conseqe are commit
those that co
ot handled pr
n immediatel
horized use, me when reprmpany premiapproved bu
ere with job pother substan
ictly prohibits. This includ
nsitive informn we provide
ing those con such federals partner thar compulsory
ode of Conduc
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quences, tted to the
over
operly, work
ly.
possession, resenting theses or at any
usiness meal performance,ce that could
ts illegal des sports
mation. We e for similar
ncerning l, state and t illegally or
y labor.
ct
7
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Givincustoan acforthHealt
ur Relatiealthcar
eractions w
ng and receivomary way tocceptable pra
h below. The th’s Policy an
Standardfollowingprofessioproducts
Policy. CVentertainsuppliers,
Permittedreasonabor prospe
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p▫ m
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ionshipe Profes
with Supp
ving reasonabo strengthen actice at CVS full Gifts and
nd Procedure
d of Ethics. Ing the highest
nal exchangeand service o
VS Health poment (such a, except as ot
d Business Mle business m
ective suppliehe supplier ohe colleague;he value of thhe venue is cousiness discu
mitted. CVS Hravel or lodgirospective su
meals, lodginguest of the co
arge scale supumber of CVrospective sur prospective
t for Services.he colleagueple, a colleagive supplier t
s with Sssionals
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ble gifts and ebusiness relaHealth unde
d Entertainmee Portal.
n interacting ethical stand
es intended tofferings of th
olicy prohibitsas tickets to stherwise prov
Meals and Entmeals or enteers provided tr prospective;
he meal or enonducive to i
ussions.
Health colleagng in connec
upplier; g, tickets or trolleague; or pplier-providS Health colle
uppliers (suche supplier.
. CVS Health e normally wogue may not hat is related
Ethics L
Suppliers, Patien
entertainmenationships. Ter certain conent Policy is a
with supplierdards and comto communiche supplier o
s the solicitatporting evenvided below.
tertainment.ertainment (sthe following
e supplier pro
ntertainmentinformationa
gues may notction with a m
ravel for the c
ed meals or eeagues are inh as departm
colleagues mould provide receive an ho
d in any way t
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rs, Cliennts & Cu
nt is a his is generaditions as set
available on C
rs and potentmplying withcate the businor prospective
tion or accepnts), travel or
CVS Healthsuch as ticketg requiremenoviding the m
is modest asal communica
t accept the fmeal or enter
colleague’s s
entertainmenn attendance
mental dinners
may not accepin the ordina
onorarium foto the colleag
S-2040 Ethics
nts, Pubustomer
lly t CVS
tial suppliersh all applicablness needs ofe supplier.
ptance by CVSlodging from
colleagues mts to sportingnts are met: meal or entert
s judged by loation and inc
following fromrtainment eve
pouse, partn
nt events in wcompared to
s or similar o
pt any form oary course of r speaking at
gue’s scope o
”Alwajudgmenteryour
C
s.BusinessCond
blic Officrs
, CVS Health le laws. Suchf CVS Health
S Health collem CVS Health’
may accept ocg events or go
tainment mu
ocal standardcludes or is co
m a supplier ent sponsore
er or significa
which a dispro the numbeutings or eve
of compensathis or her em
t an event spoof employme
ays exercment whrtainmenwork res
CVS Health Co
cials,
is committedh interactions
and the corre
eagues of gift’s suppliers o
ccasional, unolf outings) fr
ust attend the
ds; and ontiguous to
or prospectived by a suppli
ant other or a
oportionatelr of suppliers
ents) paid for
tion from a thmployment at
onsored by ant.
cise gooden engag
nt that is pponsibili
ode of Conduc
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d to s should be esponding
ts, meals, or prospective
solicited, androm supplier
e event with
legitimate
ve supplier: ier or
any other
y large s or by a supplie
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d ging in part of ties.”
ct
8
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ur Relatiealthcar
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e’s supervisors regarding wed to the Chie
sement Requor prospectivel room prior ier or prospes not viable t
e must reimbith estimate
g such repaymntation to expnd. The Emplylife/Departm
d Gifts. CVS Holicited gifts
ny gift that is ive supplier dver. Under noash equivalen
eague ming tickettend to at
s with Sssionals
pliers, con
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must indicateinvitees. If thor lavish, or o
r should not awhether a paref Complianc
uirement. In ve supplier pic
to the CVS Hective supplieto reimburse urse CVS Heaof the amounment, the CVplain the metloyee Relief Fu
ment/Commu
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does not plano circumstancnts, such as g
ust not ats to an ettend.”
Ethics L
Suppliers, Patien
ntinued
usiness Mealwriting by then three (3) bue the type of he proposed otherwise incapprove the rticular eventce Officer or h
the rare instack up a non-a
Health colleager (i.e., mealsthe supplier
alth by makinnt of the expeS Health colle
thod for estimund Contributunity%20Rela
agues may acvalue, such asominal in val
n to attend. Gces may CVS
gift cards) or d
accept anevent tha
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rs, Cliennts & Cu
ls or Entertaie colleague’s siness days aentertainmedining venu
consistent wicolleague’s rt is appropriahis/her design
ance when a allowable exp
gue’s arrival) oor entertainmor prospectiv
ng a paymentense that waeague must i
mating the vation Form for ations/Docum
ccept from sus mugs, hats oue, including
Gifts that exceHealth collea
discount from
ny gift that the sup
S-2040 Ethics
nts, Pubustomer
inment. Anymanager and
after the evennt/meal that e or entertainith the requirequest to att
ate under thisnee.
CVS Health cpense as descor in instancement provideve supplier ot to the CVS Hs funded by tinclude a recealue of the am
such donatioments/ERF/ER
uppliers and por similar inexg tickets to aneed this nomagues accept
m a supplier o
at is morepplier or p
C
s.BusinessCond
blic Officrs, contin
y meal or ented recorded in
nt. A colleaguthe supplier
nment optionrements listedtend the evens policy, the e
colleague is ucribed abovees where it is ed as part of a
on an individuHealth Emplothe supplier oeipt or other
mount being ons can be foRF_Contribut
prospective sxpensive itemn event that tinal value thrt any paymenor prospectiv
e than noprospecti
CVS Health Co
cials, nued
ertainment thn the Vendor ue’s request fhas offered a
n being offerd above, thennt. If the maevent in ques
unable to refue (i.e., a suppl
not possiblea large groupual basis), theoyee Relief Fuor prospectivreasonable paid to the E
ound on myLiionForm_v2.
suppliers on ams. A colleagthe supplier oreshold mustnt (whether ine supplier to
ominal in ve suppl
ode of Conduc
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hat is likely to
for and include red is n the nager has
stion should
use having a lier pre-paid
e to refund p offering en the und based onve supplier.
Employee ife at doc.
an occasionague must notor t be returnedn the form ofCVS Health.
value, ier does
ct
9
o
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f
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The Cinterspon
ur Relatiealthcar
eractions w
StandardfollowingprofessioHealth se
Policy. CVtheater ootherwise
Permittedmeals or ethe follow
▫ th▫ th▫ th
b Managersrequirempolicy, th
Prohibiteotherwise
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CVS Health Gractions with nsorship of cli
ionshipe Profes
with PBM
d of Ethics. Ing the highest
nal exchangervice offering
VS Health por sporting eve provided be
d Business Mentertainmen
wing requiremhe CVS Healthhe value of thhe venue is cousiness discu
s are responsents. If the me question sh
ed Entertainme noted in the
d Gifts. CVS r on no more value, such as
onal items witvalue must br his/her desigcards, are not
Gifts and Enteclients includient events.
s with Sssionals
M Clients a
n interacting ethical stand
es intended tgs and capab
olicy prohibitsents), travel oelow.
Meals and Entnt (such as ticments are meh colleague ahe meal or enonducive to i
ussions.
sible for reviemanager has ahould be refe
ment. Provide Client Foru
Health may pthan an occa
s pens, note pth CVS Healthe approved ignee. Gifts o permitted.
ertainment Poding restrictio
Ethics L
Suppliers, Patien
nd Payors
with PBM cliedards and comto communic
bilities.
s the offer or or lodging to
tertainment.ckets to sportet: attends the evntertainmentinformationa
ewing colleagany question
erred to the C
ding clients anms section of
provide to a casional basis pads, mugs ah labeling. Gn writing by t
of cash or cash
olicy has morons related to
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rs, Cliennts & Cu
s (not incl
ents, payors amplying withcate the need
provision of o CVS Health c
CVS Healthting events) t
vent with theis modest as
al communica
gue expense ns about wheChief Complia
nd payors wif the Gifts an
customer or punsolicited g
and similar inifts that are ithe Chief Comh equivalents
re informatioo client forum
S-2040 Ethics
nts, Pubustomer
luding Pu
and other cuh all applicablds of the custo
a meal, gift, ecustomers or
may provideto customers
e customer os judged by loation and inc
reports and eether a particuance Officer o
th travel or lod Entertainm
prospective gifts of
expensive n excess of mpliance s, such as
n on ms and the
C
s.BusinessCond
blic Officrs, contin
blic Offici
stomers, CVSle laws. Suchomer and the
entertainmenr prospective
e occasional, rs or prospecti
r prospectiveocal standardcludes or is co
ensuring comular event is aor his/her des
odging is proment Policy.
CVS Health Co
cials, nued
ials)
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nt (such as tice customers e
reasonable bive customer
e customer; ds; and ontiguous to
mpliance withappropriate usignee.
ohibited, exce
ode of Conduc
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mmitted to s should be ding CVS
ckets to the except as
business rs provided
legitimate
h these under this
ept as
ct
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ur Relatiealthcar
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Public Ofoften proA public ogovernmecontributpolicies, idirectly o“Anythingemploym
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ionshipe Profes
with Publ
fficials. The phibited and c
official is any ental entity, o
tions or businncluding discr indirectly, tg of value” m
ment or other
Health poctly, to a pper advan
th’s policy relPolicy for Connot intended ee (PAC).
ment Employelan Employeeovernment, oent, agency oa governmen
mployees' Retfts or entertaances, prohibr advantage aes may offer acable CVS He
e receives conment would ent employe
s with Sssionals
lic Official
provision of mcan lead to ciindividual w
or any foreigness transacticlosure requio a public off
means not onlbenefits.
olicy prohpublic offntage.”
lated to condnduct with Pto prohibit c
ees, Includinges. A governor any personor governmennt employee htirement Systinment to an
bited by law aas defined in a meal, gift oealth policiesnfirmation frobe permittede.
Ethics L
Suppliers, Patien
ls or Gove
meals, gifts oivil and/or criho is electedn governmenions, must coirements. CVficial in ordery cash, but a
hibits givifficial in o
duct with pubublic Officials
contributions
g Federal Emnment emplon or agent actnt-owned buhealth beneftem or CalPERny governmenand can lead the CVS Integr entertainme
s to a governmom the goverd under laws
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rs, Cliennts & Cu
ernment E
r entertainmiminal liabilit or appointednt. Our cond
omply with apVS Health polir to influencelso gifts, mea
ng or offorder to in
blic officials iss found on CV
s to public off
mployee Progyee is any indting in an offsiness. For p
fit plan (such Rs) is consident employee to civil and/ogrity Policy foent that is otment employrnment empand rules (su
S-2040 Ethics
nts, Pubustomer
Employees
ent to any puy if it is intend to serve on
duct with pubpplicable lawicy prohibits
e official actioals, entertainm
fering anynfluence
s contained iVS Health’s Pficials made b
gram (FEP) Emdividual empficial capacity
purposes of thas, the Feder
ered a governis highly reg
or criminal liaor Conduct wherwise permyee or agent loyee that re
uch as Codes
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blic Officrs, cont
s or Agen
ublic official ided to obtai
n behalf of a fblic officials, in
ws and regulatgiving or offe
on or obtain ament, politica
ything ofofficial ac
n a separate Policy and Proby CVS Health
mployees anployed by a fey for or on behis Code of Cral Employee
nment emploulated and, u
ability if it is inwith Public Ofmissible undeprovided thaceipt of the mof Conduct)
CVS Health Co
cials, inued
ts
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flicts of Interesequence, 17tingent workentract workers,
porate Commporate Integriomers, 3, 20,
sions. See Mapline
sciplinary action
osure, 10, 21ument(s), 10 ations, 28
dherence to this Certification is a pa
s, 11
nymously, 8, ws, 29 dering, 32
6
e, 35, 37
s, 7, 12, 35, 3
e Officer, 8, 12
y, 17 nsibilities, 35 26 Integrity Prog
mittee, 31 ption Line, 8 3
11, 26, 37, 38
est, 12 , 40 ers 7, 15, 31
munications, 2ty Agreemen32
aking Decision
n, 39
, 28
Code of Conduct irt of this requirem
38
7
2, 19, 20, 22,
gram, 35, 36,
26 nt (CIA), 33, 34
ns
is a condition of ement and failure to
25, 28, 30,
37, 38, 39,
4
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ontinued employm required time co
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ail, 9, 13, 38 ployee Relief ertainment, 1ronment, 16,cs Line, 8, 30,
Market Valuee Claims Act, ily. See Relatince, financiawalls, 27 eign Businesseign Corrupt ud, Waste andds, 28, 32
mbling, 17 s, 18, 19, 20, 2ernment overnment emp
reimbursemen
ernment reim
ardous. See Ulth, 2, 9, 10, 2lthcare Profe6, 27 pline. See Ethi
gible Health uence, 17, 21,der Trading, 1rnet, 10
estigations, 31estment Comestor, 14
C
ment with CVS Heauld result in term
Fund, 19 8, 19, 20, 21, , 17, 27, 36 , 37, 38
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ive l, 11, 36
s Dealings, 30Practices Act
d Abuse, 29, 3
21, 23, 25, 28,
ployees, Governmnt, Government
mbursement
Unsafe conditi21, 29, 31
ssionals, 18,
ics Line
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1, 35, 39 munity, 15
CVS Health Co
alth. Code of Condination of employ
22, 28, 29
0 t, 30 30, 31
, 29
ment officials, Grequests, 28, 29
requests, 33
ions
19, 20, 21, 22
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ode of Conduc
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2, 23, 24, 25,
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n House Even
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ity, 2, 22, 23 stions, 3, 8, 19
ing in this Codment changes
sion Date: Feb
dherence to this Certification is a pa
7
onsibilities, 36
s, 3, 7, 8, 14, 30, 22, 37
21, 22, 28 26
29, 31, 32, 35, 37
g. See Anti‐M
on , Non-Violence,
39
nts, 24
action Paymaims, 33 Payors, 20 tion, PHI, PII, s, 28
utions, 28 nds, 24 tices, 9
mation, 11 0, 21, 22, 28
9, 20, 22, 36, 3
de of Conduct s the at-will na
ruary, 2015
Code of Conduct irt of this requirem
6
6, 37
Money Launde
16
ent, 24
9, 10
37
constitutes a cature of your e
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ering
contract of emmployment at
mployment or coo do so within the
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ontinued employm required time co
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mbursement, tive, 12 ort, reportingorter. See Meutation, 3, 13ources, 7, 8, 2pect, 2, 16, 26ponsibilities, 3aliation, 31, 38
ty, 17 ual orientatioal Media, 26
ck tip, tippingck, Stock pricepoena, 32 stance Abusepliers, 18, 19
mporary workemination, 39, d-Party Liabil
eats, 16 de, 11, 13, 14,
afe condition
dor. See Suppations, 8, 35
vers, 8 ngdoing, 35,
th any individuts affiliates or s
C
ment with CVS Heauld result in term
retention, 11cy, 9 19, 31
g, 35 edia inquiries 3 27, 28, 35, 37 6, 36, 38, 40 3, 7, 35, 36 8
on, 16
g, 14 e, 14
e, 17
er. See Contin40 lity claims. Se
26
ns, 17
pliers
38, 39
ual. Additionasubsidiaries, w
CVS Health Co
alth. Code of Condination of employ
1, 13, 15, 32
ngent worker
ee Pay and Ch
lly, nothing inwhere applicab
ode of Conduc
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hase claims
this ble.
ct
2