Code of Conduct


Our Code of Conduct (the “Code”) reflects our collective commitment and responsibility to provide the best service, practice ethical business behavior, meet rigorous professional standards, comply with laws, regulations and policies that govern our work, and uphold our organization’s reputation. It also provides the mechanisms for asking questions and reporting concerns or suspected violations without fear of retaliation.

The Standards described in our Code below, along with our Purpose and Values, serve as guidance in promoting ethical, honest and lawful decisions and actions for us as members of Xolv Technology Solutions (“Xolv”).

This Code and its related policies may not address every possible situation you may encounter, so it is up to you to use sound judgment and seek help whenever you need it. Talk to your Supervisor, or contact People and Performance, Quality, or the Office of Risk Management (ORM) at our Shared Services Partner, Catalight, if you have any questions. In the event that more than one policy applies to any situation, all such policies will be applied to the fullest extent possible. If there is a conflict or gap in the individual policy provisions, the provisions of the policy that are most consistent with the Values of Xolv and compliance with the law will be applied.

The Code may be modified as the organization continues to grow, and the norms of client care and business practices change. The current Code is available on Xolv’s Intranet (Confluence).

Our Purpose

Developed out of direct care delivery, our innovative solutions expand our customers’ impact across the entire care experience.

We are leading a movement to transform home and community-based care. Our technology advances industry standards to create effective care paths, optimize business processes, and deliver scalable, customer-driven services.

Our Values

We are a customer-centric company that values, accountability, collaboration, integrity, and impactful innovation all while striving for excellence.


The Xolv Code of Conduct applies to every individual affiliated with Xolv Technology Solutions, including employees, interns, students, researchers and board members. It also embraces consultants and vendors when they are contracted to do business for Xolv and those who claim an affiliation or association with Xolv.

The Code of Conduct applies to all work, operations and activities of Xolv,  which might occur both on-premises and in other locations.

Your Responsibility

As members of the Xolv Community, we are each responsible for upholding these high standards in our work and professional relationships.

Duty to Report

You have an important role in assisting us with complying with laws, rules, regulations, and policies. If you have a question, concern, or suspect a violation, it is your individual responsibility to ask about it or report it to the appropriate person. Contact your Supervisor, People and Performance, or The Office of Risk Management at our Shared Services Partner, Catalight.

You may also report anonymously by calling the Xolv Compliance Helpline at 1-833-44-PROTECT (1-833-477-7683) or via the website found here.

You may ask questions or report concerns without fear of retaliation.

Additional Responsibilities of Managers and Supervisors

Managers and Supervisors have the additional responsibility of shaping a values-based culture within Xolv. You are also responsible for:

  • Staying current with regulatory changes and complying with them;
  • Ensuring alignment with Xolv Strategy, Objectives, Operational Plans and Approved Frameworks;
  • Identifying and reporting opportunities for improving operations through greater efficiency, quality, security and compliance and for promoting meaningful customer impact;
  • Ensuring your department obtains necessary licenses, permits, approvals and authorizations before action is taken;
  • Assisting your department in determining the appropriate person to notify when they have, quality, compliance, privacy, operational or other questions; and
  • Ensuring your staff completes all required training at the start of employment and subsequent mandatory annual and other periodic training.

Confidentiality and Anonymity

You can report concerns or suspected violations with your name and contact information. Xolv takes confidentiality very seriously and will maintain, to the full extent of the law, the confidentiality of the individual making the report. If an investigation is initiated, information will be shared only on a need-to-know basis. However, you may choose to report anonymously. Please note that in such cases, we will not be able to inform you of the results of the investigation.


Xolv maintains a Non-retaliation Policy that prohibits any member from retaliating against a community member who has reported a concern or suspected violation in good faith. Retaliation is subject to discipline, up to and including termination from employment and/or suspension of privileges.


We will strive to uphold the five standards below while we fulfill our role at Xolv.

Standard 1 – Quality and Safety

We expect our actions to demonstrate our care for our employees, customers and the community as a whole. Xolv is committed to providing high-quality solutions in a manner that fully complies with all applicable laws, regulations, policies and standards of care.

  • Dignity and Respect
    We deliver services with dignity and respect for each person, including our employees. We are equitable in our decisions and mindful of their impact on other groups and people.
  • Safety
    We are committed to providing and maintaining a safe, drug-free and healthy working environment for our customers, employees and members of the Community.
  • Quality
    The quality of services provided to our customers is of the utmost importance to us and we will continue to make efforts to enhance them. We will embody respect, caring, fair-mindedness and thoughtfulness in our actions towards all those we serve, the community and Xolv. We will ensure that our interactions with customers, vendors and other stakeholders continue to maintain professional boundaries so that quality and risk management at Xolv is not compromised.

Standard 2 – Privacy and Confidentiality

Privacy and confidentiality are vital to us. We will protect the privacy of our customers, employees and other stakeholders’ information, whether written, oral, electronic or image-based, and permit only such disclosures as allowed by applicable law.

We expect responsible action on behalf of the organization that is accountable and transparent to our stakeholders and to one another.

We share information when appropriate without sacrificing privacy and confidentiality.

  • Protected Health Information (PHI)
    Our healthcare customers have entrusted us with their patients’ sensitive information. We will respect the patient’s right to privacy and confidentiality. We will safeguard their PHI and request, use, share or disclose only the minimum necessary and on a need-to-know basis.

    Protected Health Information (PHI) includes any individually identifiable information that relates to past, present or future medical or behavioral conditions, treatment or payment that may identify a patient. It can be found in medical records or financial and operational systems.

    There are several federal and state laws governing the privacy and security of PHI, including the Health Insurance Portability and Accountability Act (HIPAA) and Security Rules. If you work with PHI, you should familiarize yourself with the laws and attend the training sessions offered by Xolv.
  • Personal Information
    We possess personal information such as addresses, salaries, benefits and payments of our customers, employees, interns, students, researchers, board members, consultants and vendors. We should access this information only for the fulfillment of our job requirements. We will protect their privacy and permit disclosures only as mandated by legal obligations.
  • Proprietary Information
    We do not reveal confidential information related to Xolv’s business strategies, objectives and plans, financial transactions and data, software, intellectual property and research data unless it is for a legitimate business reason and to an authorized person.
  • Security
    We are responsible for ensuring the security of the information entrusted to us. We will abide by our security policies and controls to ensure confidentiality. We will access data and facilities using our own log-in credentials, passwords and identification badges.
  • Social Media
    Xolv respects the rights of its employees and other community members to use blogs and other social media tools as a form of self-expression and communication.
    However, we will use all forms of social media appropriately and respectfully and ensure that there is no negative impact on our customers, or on our employees,  partners and affiliates (even our competitors) or other community members or on the business or reputation of Xolv.
  • Media and Public Relations Policy
    Xolv community members may not speak to or provide written comments to the media on behalf of Xolv without formal approval and media training. Requests for comment or opinion should be directed to the Communications Department.

Standard 3 – Personal Conduct and Business Ethics

We expect to be treated and to treat others with respect.

We respect the opinions of and the differences among individuals.

We expect fairness to be evident in our actions internally and externally.

  • Gifts and Gratuities
    Community members of Xolv should discourage accepting gifts from customers and business associates. In rare instances, community members may accept gifts that are of nominal value, perishable and are to be shared with office staff, e.g., cakes, brownies, chocolates, flowers, fruits, etc. Gifts of a personal nature, such as perfume and clothing, are not permitted. Under no circumstances will any member accept cash or cash equivalent as gifts, e.g., gift cards, dining vouchers, tickets to sports, golfing or other entertainments, stocks, bonds, etc.
  • Gifts and Business Courtesies from Vendors
    Community members of Xolv are discouraged from offering or receiving gifts from vendors even if such gifts are occasional, of nominal value, and perishable. In rare instances, gifts such as cakes, chocolates, flowers, etc., which are to be shared with office staff might be accepted.
    Under no circumstances might any community member offer or receive a gift when the intent is to generate business or influence a Xolv decision.
  • Conflict of Interest
    Xolv community members are expected to act at all times in the best interest of the organization and its customers. Employees and staff should avoid engaging in outside activities that might compromise or negatively impact their job performance.

    We will strive to avoid conflict of interest, or perception of such, in all aspects of our work.

    We will not use our professional positions to assert undue influence or obtain unreasonable services from others. Nor will we aim to gain personally from our role at Xolv.

    We will maintain all contractual relationships, both current and potential, in a legal and ethical manner.

    A conflict of interest occurs if outside activities or personal interests influence, or appear to influence, the ability to make objective decisions on behalf of Xolv. Employees, interns, students, researchers and board members should disclose any situation where there is an actual conflict or a potential conflict to the Compliance and Risk Officer.

    We will refrain from personal fundraising in the workplace.
  • Discrimination, Diversity and Inclusion
    We respect diversity within our workplace and promote inclusion. We practice fair and equal treatment of employees, interns, students, researchers and board members. Vendors and consultants are expected to abide by our standards.

    You are expected to report abuse, violence, harassment or intimidation of any kind that you witness or experience in the workplace.
  • Stewardship
    We will be good stewards of the resources entrusted to our care. We will be respectful of Xolv’s property, equipment, supplies and assets and will use them judiciously within the scope of our job responsibilities and to further the mission of the organization.
  • Duty of Regard
    We will ensure that only personnel authorized by policy and agreement bind or commit Xolv (including the witnessing of documents) to obligations that align with the mission and vision of the organization. We will not bring personal property into the workplace that is offensive to others. We will not use Xolv electronic mail or other property to convey or communicate inappropriate material. We will strive to ensure that all promotions and marketing of our services are in accordance with the values of our organization’s guidelines while being respectful and sensitive to the needs of our customers and our other stakeholders.

Standard 4 – Compliance with Laws and Regulations

Xolv’s customers may include companies that are highly regulated. It behooves each of us to ensure that our professional conduct is in accordance with applicable laws, regulations and policies, especially those relating to the handling of sensitive customer information, vendor contracts, lobbying, environmental health and safety, employment practices, etc. These laws and regulations are complex; hence, Xolv provides regular training and policies. It is your responsibility to ensure that you complete the training required and refer to policies when the need arises.

We expect compliance with applicable laws and regulations.

We will avoid fraud, waste and abuse.

  • Fraud, Waste and Abuse Laws
    Fraud, waste, and abuse (FWA) laws prohibit certain practices.

    Fraud is defined as the wrongful or criminal deception intended to result in financial or personal gain. Fraud includes false representation of fact, making false statements, or by concealment of information.

    Waste is defined as the thoughtless or careless expenditure, mismanagement, or abuse of resources to the detriment (or potential detriment) of the U.S. government. Waste also includes incurring unnecessary costs resulting from inefficient or ineffective practices, systems, or controls.

    Abuse is defined as excessive or improper use of a thing, or to use something in a manner contrary to the natural or legal rules for its use. Abuse can occur in financial or non-financial settings.

    We are committed to using the organization’s funds, time and other resources judiciously without leading to fraud, waste, or abuse, and in accordance with achieving the organization’s mission.
  • Environmental Safety
    We will endeavor together to provide and maintain a safe, drug-free and healthy working environment for our customers, employees and other community members. We will operate and maintain equipment, facilities and processes in a safe manner.
  • Cooperation with Government Investigations
    We will respectfully cooperate with all government auditors and investigators.
    You should immediately bring any requests for information, which may include audit requests, search warrants, subpoenas, civil investigative demands, and similar to the attention of your supervisor or the Office of Risk Management (ORM).

In situations where the Xolv community members participate in political affairs, it is required that they make clear that they are acting as private citizens and not on behalf of Xolv. If the community member chooses to contribute to a political campaign, it should be as an individual and not as a Xolv representative.

Standard 5 – Financial Reporting

We will be responsible and accountable for our actions and decisions.

We will conduct business in accordance with accepted business practices.

  • Accuracy and Completeness
    We will make every effort to ensure accuracy, completeness and timeliness in our accounts, financial reports, tax returns, expense reimbursements, time sheets and other documents, including those submitted to government agencies and other stakeholders. All entries should reflect the precise nature of the activities and transactions of the business and be free from error.
  • Audits and Monitoring
    We will commit to annual audits by an independent agency to ensure the financial integrity of our records and accurate filings with government agencies.

    We will monitor and analyze our financial and other information to ensure the appropriate use of monies for the achievement of organizational goals.

Last Updated: January 2024