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Vendor Code of Business Conduct & Ethics – 2022

Horizon Blue Cross Blue Shield of New Jersey, including its subsidiaries and affiliates (collectively, “Horizon BCBSNJ”), operates under high standards of conduct and we comply with all applicable laws, rules, regulations and subregulatory guidance. This includes always taking the proper steps to safeguard our members' information. We expect the same level of conduct from all individuals, companies or others, working for, or on behalf of, Horizon BCBSNJ, directly or indirectly.

Horizon BCBSNJ's Vendor Code of Business Conduct and Ethics (“Vendor Code”) contains the general principles with which vendors must follow when doing business with us. The Vendor Code describes who is considered a “vendor” and includes descriptions of some of the laws that must be complied with.

Vendors are responsible for ensuring that their workforce members, as described in the Vendor Code, comply with the standards contained therein and with any more restrictive requirements set forth in the business agreement with Horizon BCBSNJ.

Please take the time to become familiar with the principles of the Vendor Code. Compliance is an important job and we want to be sure that you understand what is required of you.

Should you have any questions, please refer them to your Horizon BCBSNJ business contact or to one of the contacts listed on Supplier Resources.

We look forward to working with you and thank you for your ongoing commitment to compliance, ethics and excellence Horizon BCBSNJ is known for.

Vendor Code of Business Conduct & Ethics – 2022

Horizon BCBSNJ has a reputation for doing business with a commitment to honesty, ethics and excellence, and in compliance with all applicable laws, regulations and sub-regulatory guidance. Operating under consistently high standards of conduct is critical to Horizon BCBSNJ's success and all Vendors¹ are expected to conduct themselves accordingly. Vendors are responsible for ensuring that their employees, agents, contractors, consultants, temporary workers, volunteers and employees of subcontractors (“Workforce Members”) comply with the standards of conduct as described in this Vendor Code. Horizon BCBSNJ will request information, as necessary, from the Vendor to ensure such compliance.

Compliance with the Law

Compliance with Horizon BCBSNJ Policies and Procedures

Reporting Potential Misconduct

Fraud, Waste, Abuse, Dishonesty and Criminal Conduct

Non-Retaliation

Avoiding Conflicts of Interest

Gifts and Courtesies

Respect and Integrity in the Workplace

Protecting Horizon BCBSNJ Assets

Safeguarding Horizon BCBSNJ Information

Passwords and Access

Books and Records

Horizon BCBSNJ's Intellectual Property

Intellectual Property Rights of Others

Fair Competition and Business Practices

Interacting with the Government

Federal Health Care Programs

Compliance Contacts

Key Regulatory Requirements

Note: This Vendor Code sets forth general principles with which Vendors must comply. More restrictive requirements may be set forth in the business agreement with Horizon BCBSNJ. In addition, this Vendor Code will be automatically amended to incorporate any change or modification of applicable state or federal law, regulation or standard as of the effective date of the change or modification.

[¹] The term “Vendors” includes all individuals, companies or others working for, or on behalf of, Horizon BCBSNJ directly, or indirectly and all suppliers, vendors, health care providers, pharmacies and first-tier, downstream and related entities and their vendors.