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					DEPARTMENT: Ethics and Compliance                POLICY DESCRIPTION: Entertainment
PAGE: 1 of 3                                     REPLACES POLICY DATED: April 1, 1998
APPROVED: July 11, 2000                          RETIRED:
EFFECTIVE DATE: August 15, 2000                  REFERENCE NUMBER: EC.006


SCOPE: All Company-affiliated facilities including, but not limited to, hospitals, ambulatory
surgery centers, home health agencies, physician practices, and all Corporate Departments, Groups
and Divisions.

PURPOSE: To establish application rules related to business courtesies.
_______________________________________________________________________________
POLICY: The essential policy for business courtesies is set forth in the Code of Conduct, and the
relevant provision is appended hereto. This policy is intended to offer a limited number of
application rules to the provisions in the Code of Conduct.

A critical distinction should be made between three types of activities:

1. Business meetings at which a meal is served are not considered business courtesies and are
   not subject to the business courtesy provisions in the Code of Conduct or this policy. This
   exclusion applies in both the case of our hosting or attending business meetings.

2. Entertainment implies a social event (e.g., a meal, attendance at a sporting or cultural event,
   participation in a sporting activity) at which business matters are discussed but where it is
   apparent that the event is not intended as a business meeting. All business entertainment must
   include some discussion of business.

3. Participation in longer events (events of a day or more in duration), such as vendor-sponsored
   training or conferences, is governed by the Vendor-Promotional Training Policy, EC.007. It is
   anticipated that the company would not host free of charge longer events other than for
   voluntary leadership of hospitals (e.g., Board retreats or meetings), and such events are
   governed by the Reimbursement of Expenses Related to Voluntary Leadership Service by
   Physicians Policy, EC. 009. In the rare circumstance the company seeks to host a longer event
   for a group of non-company employees other than hospital voluntary leadership, such events
   should be approved in advance by the Senior Vice President for Ethics, Compliance and
   Corporate Responsibility.

PROCEDURE:
Extending invitations of entertainment:

If it was anticipated the cost per person of a business entertainment activity would not exceed
$100, but the cost per person appears to have exceeded $100, a report must be filed with the
Division President and a copy sent to the Senior Vice President for Ethics, Compliance and


8/7/2000
DEPARTMENT: Ethics and Compliance                 POLICY DESCRIPTION: Entertainment
PAGE: 2 of 3                                      REPLACES POLICY DATED: April 1, 1998
APPROVED: July 11, 2000                           RETIRED:
EFFECTIVE DATE: August 15, 2000                   REFERENCE NUMBER: EC.006


Corporate Responsibility. For any ticketed event, the cost of the event is the face value of the
ticket unless the facility actually paid more, in which case the cost is the amount actually paid. For
a charity event, the cost of the event is the fair market value of the activity provided as opposed to
the full amount of the ticket (i.e., the amount of the charitable contribution may be excluded from
the value of the entertainment provided to the colleague or business associate).

If a business entertainment activity entails two events that are reasonably viewed as being different
events but which are consecutive (e.g., a dinner followed by attendance at a cultural function), the
$100 limit may be applied separately to each of the two events provided, however, this is regarded
as two occurrences of entertainment with regard to the general guideline that any entertainment
offered to a business associate should occur not more than four times a year.

If, prior to hosting a business entertainment activity, it is anticipated the cost per person will
exceed $100, one must receive advance approval from the facility ECO and the Division President.
A copy of the approval should be provided to the Senior Vice President for Ethics, Compliance
and Corporate Responsibility. Colleagues at Corporate headquarters and Group and Division
offices must receive such advance approval from their supervisor and the Senior Vice President for
Ethics, Compliance and Corporate Responsibility.

Accepting invitations of entertainment:

If it was anticipated the cost per person of a business entertainment activity would not exceed
$100, but the cost per person appears to have exceeded $100, a report must be filed with the
Division President or supervisor at the Corporate headquarters, Group or Division offices, as
appropriate, and a copy sent to the Senior Vice President for Ethics, Compliance and Corporate
Responsibility. All events occurring on the same day and offered by the same individual or entity
are considered the same event and must fall within the $100 limit. For any ticketed event, the cost
of the event is the face value of the ticket unless the receiver has knowledge the giver paid more
than the face value, in which case the cost is the amount actually paid. For a charity event, the cost
of the event is the fair market value of the activity received as opposed to the full amount of the
ticket (i.e., the amount of the charitable contribution may be excluded from the value of the
entertainment provided to the colleague).

Requests for advance approval to accept invitations of entertainment that exceed $100 must be
submitted to one’s supervisor and the facility ECO. Colleagues at Corporate headquarters and
Group and Division offices must submit their request to the Senior Vice President, Ethics,
Compliance and Corporate Responsibility. Such requests will be granted only in unusual


8/7/2000
 DEPARTMENT: Ethics and Compliance                POLICY DESCRIPTION: Entertainment
 PAGE: 3 of 3                                     REPLACES POLICY DATED: April 1, 1998
 APPROVED: July 11, 2000                          RETIRED:
 EFFECTIVE DATE: August 15, 2000                  REFERENCE NUMBER: EC.006


 circumstances.

 It is not permissible to pay part of the cost of entertainment that is offered with a value exceeding
 $100 to reduce the value to less than $100 and then accept the entertainment. However, it is
 acceptable to pay the full value of such an entertainment activity and then participate in the event.
________________________________________________________________________________
 REFERENCES:

 Code of Conduct, Business Courtesies Section
 Vendor Promotional Training Policy, EC.007
 Expenses Related to Voluntary Leadership Service by Physicians Policy, EC.009




8/7/2000
                                                                                 Draft Revised Code

                                        Business Courtesies

General
This part of the Code of Conduct should not be considered in any way as an encouragement to
make, solicit, or receive any type of entertainment or gift. For clarity purposes, please note that
these limitations govern activities with those outside of HCA. This section does not pertain to
actions between HCA and its colleagues or actions among HCA colleagues themselves. (See
“Relationships Among HCA Colleagues” on page 14.)

Receiving Business Courtesies
We recognize there will be times when a current or potential business associate may extend an
invitation to attend a social event in order to further develop your business relationship. You may
accept such invitations, provided: (1) the cost associated with such an event is reasonable and
appropriate, which, as a general rule, means the cost will not exceed $100.00 per person; (2) no
expense is incurred for any travel costs (other than in a vehicle owned privately or by the host
company) or overnight lodging; and (3) such events are infrequent. The limitations of this section
do not apply to business meetings at which food (including meals) may be provided. Sometimes a
business associate will extend training and educational opportunities that include travel and
overnight accommodations to you at no cost to you or HCA. Similarly, there are some
circumstances where you are invited to an event at a vendor’s expense to receive information
about new products or services. Prior to accepting any such invitation, you must receive approval
to do so consistent with the corporate policy on this subject.

As an HCA colleague, you may accept gifts with a total value of $50.00 or less in any one year
from any individual or organization who has a business relationship with HCA. For purposes of
this paragraph, physicians practicing in HCA facilities are considered to have such a relationship.
Perishable or consumable gifts given to a department or group are not subject to any specific
limitation. You may accept gift certificates, but you may never accept cash or financial
instruments (e.g., checks, stocks). Finally, under no circumstances may you solicit a gift.

This section does not limit HCA facilities from accepting gifts, provided they are used and
accounted for appropriately.

Extending Business Courtesies to Non-referral Sources
No portion of this section, "Extending Business Courtesies to Non-referral Sources," applies to
any individual who makes, or is in a position to make, referrals to a HCA facility.

There may be times you wish to extend to a current or potential business associate (other than
someone who may be in a position to make a patient referral) an invitation to attend a social event
(e.g., reception, meal, sporting event or theatrical event) to further or develop your business
relationship. The purpose of the entertainment must never be to induce any favorable business
action. During these events, topics of a business nature must be discussed and the host must be
present. These events must not include expenses paid for any travel costs (other than in a vehicle
owned privately or by the host entity) or overnight lodging. The cost associated with such an event
must be reasonable and appropriate. As a general rule, this means the cost will not exceed $100.00
per person. Moreover, such business entertainment with respect to any particular individual must
be infrequent, which, as a general rule, means not more than four times per year.

With regard to the $100.00 guideline, if circumstances arise where an entertainment event was
contemplated prior to the event to meet the guideline but unforeseeably exceeded it, a report to
that effect with the relevant details must be filed consistent with the corporate policy on this
subject. If you anticipate an event will exceed the $100.00 guideline, you must obtain advance
approval as required by corporate policy. That policy requires establishing the business necessity
and appropriateness of the proposed entertainment. The organization will under no circumstances
sanction participation in any business entertainment that might be considered lavish. Departures
from the $100.00 guideline are highly discouraged.

Also, HCA facilities may routinely sponsor events with a legitimate business purpose (e.g.,
hospital board meetings or retreats). Provided that such events are for business purposes,
reasonable and appropriate meals and entertainment may be offered. In addition, transportation
and lodging can be paid for. However, all elements of such events, including these courtesy
elements, must be consistent with the corporate policy on such events.

It is critical to avoid the appearance of impropriety when giving gifts to individuals who do
business or are seeking to do business with HCA. We will never use gifts or other incentives to
improperly influence relationships or business outcomes. Gifts to business associates who are not
government employees must not exceed $50.00 per year per recipient The corporate policy on
business courtesies may from time to time provide modest flexibility in order to permit
appropriate recognition of the efforts of those who have spent meaningful amounts of volunteer
time on behalf of HCA.

U.S. Federal and state governments have strict rules and laws regarding gifts, meals, and other
business courtesies for their employees. HCA’s policy is to not provide any gifts, entertainment,
meals, or anything else of value to any employee of the Executive Branch of the Federal
government, except for minor refreshments in connection with business discussions or
promotional items with the HCA or facility logo valued at no more than $10.00. With regard to
gifts, meals, and other business courtesies involving any other category of government official or
employee, you must determine the particular rules applying to any such person and carefully
follow them.

Extending Business Courtesies to Possible Referral Sources
Any entertainment or gift involving physicians or other persons who are in a position to refer
patients to our healthcare facilities must be undertaken in accordance with corporate policies. We
will comply with all Federal laws, regulations, and rules regarding these practices.




                                                 2                              Attachment to EC.006

				
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