These Business Ethics and Conflict of Interest policies establish the rules of conduct for persons who are officers and employees of Pinnacol Assurance. They are intended to provide guidance to these parties in fulfilling their ethical and legal responsibilities in their work. Compliance with these policies is a condition of employment at Pinnacol Assurance.

Ethics

The business of Pinnacol Assurance shall be conducted with honesty and integrity and in accordance with the highest ethical and legal standards. The employees and officers of Pinnacol each have a responsibility to ensure that these principles are applied to every aspect of the business.

Compliance with law

All employees and officers of Pinnacol should respect and comply with all of the laws, rules, and regulations of the United States and the state of Colorado in which Pinnacol conducts its business, and the laws, rules, and regulations which are applicable to Pinnacol generally.

Conflict of Interest

Pinnacol Assurance will not permit, and has never permitted undisclosed, conflicts of interest on the part of its employees or officers. Accordingly, no employee or officer shall knowingly become involved in a conflict of interest without proper reporting and authorization or, upon discovery thereof, allow such an unauthorized conflict to continue. Even if an employee believes that a Conflict already exists, it is vital that the employee disclose those conflicts immediately as set forth in Sections V and VI. Pinnacol will not tolerate any direct interest in, connection with, or benefit from, any outside activity, which interest might in any way affect the company without prior knowledge and written approval of Pinnacol. Such conflict of interest shall include, but is not limited to:

A. Involvement with suppliers, contractors, or customers.

  1. Ownership of a material interest in any supplier, contractor, subcontractor, customer, or other entity with which Pinnacol does business. Before any invitation to a Pinnacol employee to serve on the board of directors of another business entity is accepted, it must be approved by Pinnacol. This approval is required to provide assurance that the proposed directorship will not interfere with the performance of the employee's duties or conflict with Pinnacol's position on ethics and investments.
  2. Acting as a director, officer, partner, consultant, employee, distributor, agent, or the like - for suppliers, contractors, subcontractors, customers, or other entities with whom Pinnacol does business without prior written approval from the employee's manager.
  3. Acceptance, directly or indirectly, of payments, services, or loans from a supplier, contractor, subcontractor, customer, or other entity with whom Pinnacol does business. The foregoing shall be deemed to include gifts, trips, entertainment, or other favors of more than nominal value, but shall exclude loans from publicly-held insurance companies and commercial or savings banks at normal rates of interest.
  4. Employees will immediately notify their direct manager when they have knowledge, or receive notice that a relative is involved in a business transaction with Pinnacol. A business transaction may include a claimant who is an injured worker of an employer covered by Pinnacol; business owner, officer, or director of a company that is seeking coverage from Pinnacol, medical provider performing service for Pinnacol, agent representing Pinnacol, vendor seeking business, etc. with Pinnacol. This notification needs to be in writing and done immediately when the situation described occurs. This policy applies whether the employee is directly involved in the business transaction or not. This notice will allow all parties to the business transaction to be aware of the relationship and identify potential conflict of interest situations.

 

B. As an employee at Pinnacol you may have access to confidential information. Confidential information includes proprietary information of the company, claimant information and policyholder information. You may learn of or have access to some or all of this confidential information through a computer system or through your employment activities.

Security and confidentiality is a matter of concern for all persons who have access to Pinnacol information. Each person accessing Pinnacol data and resources holds a position of trust for this information and must recognize the responsibilities entrusted in preserving the security and confidentiality of this information. Therefore, as a person who is authorized to access Pinnacol data and resources you must read and comply with Pinnacol policies which explain your obligations in this area.

  1. Use of such information or facilities in a manner, which will be detrimental to the interests of Pinnacol, e.g., utilization for one's own benefit of know-how or information developed through an employee's employment with Pinnacol.
  2. Disclosure or other misuse of confidential, unpublished information, or trade secrets of any kind obtained through an individual's employment or other connection with Pinnacol, unless expressly authorized in writing by the CEO; if this involves the CEO, then the Governance and Ethics Committee.
  3. Failure to protect the confidentiality of all of Pinnacol's records and information including, but not limited to: all claimant-specific and medical provider-specific medical records and information, and all records and information concerning Pinnacol's internal business matters including policyholder records and information. Such records and information shall be disclosed only in compliance with applicable federal and state laws, including the Colorado Workers' Compensation Act and the Rules of Procedure adopted in relation to that Act and when needed by regulatory agencies for investigation of complaints and grievances filed against medical providers. Claimant-specific and provider-specific information may be used to support Pinnacol's network quality management and credentialing programs but only when specifically authorized by Pinnacol.
  4. Unauthorized disclosure of Pinnacol's Trade Secrets is a violation of the Colorado Criminal Code and may also subject an employee to a civil action for damages according to Sections 18-4-408 and the Uniform Trade Secrets Act, Section 7-74-101, et. Seq. Colorado Revised Statutes.
  5. Use of Pinnacol property, equipment, or supplies for private use not in the interest of Pinnacol. All employees and officers should protect Pinnacol's assets and ensure their efficient use. Theft, carelessness and waste have a direct impact on Pinnacol's profitability. All company assets should only be used for legitimate business purposes.
  6. Personal appropriation of corporate opportunities that properly belong to Pinnacol or are discovered through the use of corporate property, information or position.

 

C. Interest in or position with a competitor.

  1. Ownership, directly or indirectly, by an employee or officer of a material interest in an enterprise in competition with Pinnacol.
  2. Acting as a director, officer, partner, consultant, employee, or agent of any enterprise which is in competition with Pinnacol.

 

D. Disclosure of conflicts of interest. Any employee who is aware of facts which might involve the slightest possibility or appearance of a conflict of interest shall immediately report, in writing, such details to his or her team leader.

Pinnacol employees will not undertake new commitments which have the potential of a conflict of interest without prior approval of their team leader. The reviewing team leader must discuss any questionable commitment with the appropriate Vice President or CEO before extending written approval to the employee.

Pinnacol recognizes that there may be borderline situations.

  1. Each case shall be approached objectively, giving full recognition to the circumstances.
  2. In some instances, full disclosure of the facts by the employee is all that is necessary to enable Pinnacol to protect its interest. If no improper motivation appears to exist, and Pinnacol's interests have not suffered, full disclosure may suffice.
  3. Pinnacol's determination as to whether a conflict of interest exists shall be conclusive. Pinnacol reserves the right to take such action as, in its judgment, will end the conflict.

Financial Transactions

Pinnacol's policy is to comply with all applicable financial reporting and accounting regulations applicable to the company. If any employee or officer of Pinnacol has concerns or complaints regarding questionable financial reporting or accounting, then he or she is encouraged to promptly submit those concerns or complaints in writing to his or her team leader, or a Vice President, or a compliance officer. The compliance officers are Carole Sumption and Sharra Lee Leonard. Carole Sumption may be reached as follows: Her direct line is 303.361.4961. Her email is carole.sumption@pinnacol.com. Sharra Lee Leonard may be reached as follows: Her direct line is 303.361.4687. Her email is sharralee.leonard@pinnacol.com. If the employee or officer is not satisfied with the response from these parties, or believes that bringing the problem to these parties would be futile, the person is encouraged to submit these concerns to the CEO and/or the Governance and Ethics Committee. That committee can be reached at the following internal Pinnacol email address: Governance and Ethics Committee.

Reporting of Other Violations

Any violations of these policies or other observed illegal or unethical conduct by employees or officers of the company, including but not limited to claims handling and underwriting, must be reported promptly to the following individuals: the employee's team leader, or the Vice President, or a compliance officer. The compliance officers are Carole Sumption and Sharra Lee Leonard. Carole can be reached at 303.361.4961, and Sharra Lee can be reached at 303.361.4687.

If the employee or officer is not satisfied with the response from these parties, or believes that bringing the problem to these parties would be futile, the person is encouraged to submit these concerns to the CEO and/or the Governance and Ethics Committee. That committee can be reached at the following internal Pinnacol email address: Governance and Ethics Committee.

Employees are encouraged to talk to team leaders or other appropriate personnel about observed illegal or unethical behavior when in doubt about the best course of action in a particular situation.

Any such team leader or any officer of Pinnacol who receives or obtains information that illegal or unethical conduct or a violation of these policies has occurred must immediately report this information to a Compliance Officer.

SilentWhistle is available to anyone needing to confidentially report concerns. In order to access the hotline, connect to the internet from a computer anywhere by typing www.pinnacol.alertline.com. Select Pinnacol Assurance from the list provided. Select the method of anonymous communication or call 1-877-874-8416 to speak with a live hotline operator.

Consequences for Non-Adherence to Policies

Upon receiving a report of illegal or unethical conduct or a violation of these policies, a Compliance Officer or a designee thereof will investigate the allegation, giving the alleged violator an opportunity to be heard. An employee, or officer deemed to have violated a provision of these policies may be subject to disciplinary action, up to and including termination and/or a requirement that the violator reimburse Pinnacol for any damage it may have suffered.

No Retaliation

Pinnacol will not permit retaliation of any kind by or on behalf of the company and its employees and officers against good faith reports or complaints of violations of these policies or other illegal or unethical conduct.

If the employee believes that bringing the problem to these parties would be a conflict, the person is encouraged to submit Business Ethics and Conflict of Interest concerns to the CEO and/or the Governance and Ethics committee.

 

View our Business Ethics and Conflict of Interest Process