2021 CORPORATE RESPONSIBILITY REPORT I 67 Quest’s vision is to empower better health through diagnostic insights. Our ability to achieve that vision is dependent on one of our key values, integrity. We strive to operate ethically, honestly, and responsibly, in accordance with our Code of Ethics. Our commitment to ethical business conduct We are committed to adhering to all applicable laws and regulations in our work as a healthcare leader. We have a clear strategy to maintain a culture of compliance and integrity at Quest that engages all our employees and emphasizes the importance of ethical behavior through our policies, training, assessments, and reporting practices. Policies Quest’s Code of Ethics is critical to our success, empowering us with the roadmap we need to earn and maintain the trust of our patients, customers, shareholders, and colleagues. Our Code is not merely a set of rules—it defines our approach to making good decisions no matter what our role is and creates a shared sense of pride among all of us. Our Code and compliance policies apply to all employees, subsidiaries, vendors, contractors, suppliers, interns, business partners, and representatives who work on our behalf. We expect the best from ourselves and one another, including a commitment to Quest’s core values of leadership, integrity, quality, innovation, collaboration, and accountability. We expect one another to ask questions and take action if something isn’t right. Employees who have concerns are encouraged to share them with their manager; a representative from our Human Resources, Compliance, or Legal departments; or confidentially or anonymously through our hotline or online inquiry form. Training We look to our managers and supervisors to always promote our Code and model the right behaviors. This includes creating an open-door environment, making it clear that any form of retaliation is unacceptable when an employee raises concerns, ensuring employees are properly trained, and being fully present to offer guidance and support. All full-time, part-time, and contract employees are required to complete training upon hire as well as on an ongoing, annual basis. The training topics include compliance, fraud, and abuse; privacy; corruption; bribery; and our Code of Ethics. Select employees are also trained on compliance with the Foreign Corrupt Protection Act (FCPA). Our compliance training program is reviewed as part of our internal audit process, with select segments overseen by our Legal department. Risk assessment The best way to assess compliance risks—and the capacity to effectively address those risks—is to do so consistently and continuously throughout the year. We expect all employees to identify any compliance issues within their areas of responsibility. The company engages in an annual risk assessment specific to compliance, assessing and categorizing compliance risks regarding severity and the level of mitigation required. The Compliance Risk Assessment is conducted at the direction of counsel and is an element of the enterprise risk management (ERM) program. Integrity: a fundamental value TABLE OF CONTENTS 2021 OVERVIEW COVID-19 RESPONSE PROMOTING A HEALTHIER WORLD CREATING AN INSPIRING WORKPLACE BUILDING VALUE REFERENCES
Quest Diagnostics Corporate Responsibility Report Page 66 Page 68