Code of Conduct

Jubilant DraxImage Radiopharmacies, Inc. dba Triad Isotopes. A Jubilant Pharma Ltd. Company (referred to within this docuement as "Jubilant") does everything it can to deliver the highest quality nuclear pharmacy services to its customers and ultimately, to the individual patients who receive radiopharmaceuticals from our network of pharmacies. All of Jubilant's nuclear pharmacy services must be delivered in compliance with all laws and rules and, more important, with the highest professionalism and integrity. The Company's Code of Conduct was developed to help each of Jubilant's team members make good decisions about their daily activities, so the Jubilant organization can meet these objectives.

This Code of Conduct will never be a substitute for common sense and personal integrity, but it has been put together to spell out a basic set of minimum standards that all Jubilant team members are required to follow every day. These standards are the basis of the Company's values-based compliance program and failure to follow these standards will result in disciplinary action and/or termination of employment.

If any of these basic standards are unclear, or if a team member is not sure whether they apply to a particular situation that they encounter as a Jubilant team member, they should ask their supervisor, discuss the situation with Jubilant's Chief Compliance Officer, or ask the question by calling the Jubilant Compliance Hotline at any time. The number is 1-877-738-7423. No question is too basic and no action of retaliation or reprisal will be taken against any Jubilant team member for calling the Jubilant Compliance Hotline to make a report, a complaint or initiate an inquiry.


Condition of Employment

The policies incorporated into Jubilant's Code of Conduct are mandatory and must be followed. Failure to comply with any of the provisions of this Code of Conduct will result in disciplinary action, up to and including termination of employment with Jubilant or cancelation of contractual or business relationships with customers, contractors and agents.


Work Environment

Jubilant is committed to providing a safe and healthy workplace for all employees, customers and visitors. Supervisors, Managers and Administrators must establish and maintain an environment in their work area and areas of control in which compliance with laws and regulations is required and is part of the workplace culture. Jubilant has developed policies to protect employees from potential workplace hazards, including, but not limited to, sound radiation protection principles to achieve occupational and member of public doses that are as low as reasonably achievable (“ALARA”).

It is important for team members to advise their supervisor of any serious workplace injury or any situation presenting a danger of injury so that timely corrective action can be taken to resolve the issue(s).


Harassment/Intimidation

Each Jubilant team member, customer or visitor has the right to work and visit an environment that is free of harassment or intimidation of any kind. Jubilant will not tolerate harassment of anyone by Jubilant team members, customers or visitors at any time, inside or outside the Jubilant workplace. Degrading or humiliating jokes, slurs, intimidation or other harassing behavior will not be tolerated. Prohibited harassment includes, but is not limited to, any harassment or inappropriate behavior based upon any individual’s race, national origin, sex, age or religious beliefs. Unwelcome sexual advances and requests for sexual favors in conjunction with employment decisions are prohibited and any verbal, written or physical conduct of a sexual or intimidating nature that interferes with any individual’s dignity or work performance or that create an intimidating, hostile or offensive workplace will not be tolerated.

It is important for team members to advise their supervisor of any harassment or intimidation situation, so that timely corrective action can be taken to resolve the issue(s).


Workplace Violence

All Jubilant team members have the right to work in an environment that is free of violence. Jubilant has adopted a Workplace Violence Policy that is contained in the Jubilant Team Member Handbook that is given to all Jubilant team members. In addition, Jubilant will not tolerate any of the following activities by Jubilant team members, customers or visitors of Jubilant within a Jubilant facility or while performing activities on behalf of Jubilant at any location:

  • Robbery, terrorism, hate crimes, property destruction, identity theft, stalking, physical violence or the threat of physical violence directed at individuals or Jubilant itself.
  • Licensed or unlicensed possession of any weapons, explosives or other dangerous materials while on any Jubilant property, including all parking areas used by Jubilant team members, while operating a Jubilant vehicle or while on Jubilant business at any location.

It is important for team members to advise their supervisor of any possible or actual workplace violence situation, so that timely corrective action can be taken to resolve the issue(s).


Professional Licenses

All Jubilant team members and independent contractors of Jubilant that are required to have valid, personal state or federal permit(s), license(s) or registration(s) to perform their duties on behalf of Jubilant, shall maintain them in good standing at all times while they are employees or contractors of Jubilant. These team members and contractors shall also comply with all applicable laws, rules and regulations, continuing education obligations and professional standards at all times while employed or contracted by Jubilant. No Jubilant team member or contractor will be allowed to perform their job functions at any time that their personal permit(s), license(s) or registration(s) are not in good standing with the applicable state or federal agencies that issued them.

Each Jubilant team member or independent contractor shall notify their supervisor immediately if any action is taken by any agency or court of law that may impact their personal permit(s), license(s) or registration(s) and/or their ability to perform their job functions on behalf of Jubilant. Each Jubilant team member and independent contractor will also supply any written correspondence or other documents that they receive from any agency or court of law that may impact their personal permit(s), license(s) or registration(s) to their supervisor immediately upon receipt and upon request at any time.


Hiring of Excluded Individuals

Jubilant will not knowingly hire or engage any individual or organization as a subcontractor, consultant or supplier that has been excluded from participation in any government healthcare programs. Jubilant will check each prospective Jubilant team member  against the Department of Health and Human Services Office of Inspector General Fraud Exclusion Database, (located at http://exclusions.oig.hhs.gov/), as part of the Jubilant pre-employment screening process. Jubilant will also check all organizations, subcontractors, consultants or suppliers against the same database before finalizing any contractual relationships with such organizations.

It is important for team members to advise their supervisor of any information about any excluded individuals or organizations that they are aware of that have any relationship with Jubilant, so that timely corrective action can be taken to resolve the issue(s).


Substance Abuse

Jubilant shall maintain a strict alcohol and drug free workplace for the safety of all Jubilant team members, Jubilant guests, Jubilant customers and patients and the general public. An alcohol and drug free workplace will be achieved by enforcing the Jubilant Substance Abuse Policy contained in the Jubilant Team Member Handbook that is distributed to all Jubilant team members when they are hired.

It is important for team members to advise their supervisor of any substance abuse that they observe, so that timely corrective action can be taken to resolve the issue(s).


Environmental Compliance

Jubilant shall use its best efforts to protect the environment and shall obtain all required permits, licenses and registrations to handle, store and dispose of, all of the substances that Jubilant utilizes in the normal course of business. Jubilant shall also comply with all applicable environmental laws, rules and regulations and all Jubilant team members are required to handle all radioactive materials, bio-medical waste and hazardous wastes generated by Jubilant in compliance with all such laws, rules and regulations and the rules and regulations of any waste disposal organizations that Jubilant utilizes on a regular basis.

It is important for team members to advise their supervisor of any environmental issues that they observe, so that timely corrective action can be taken to resolve the issue(s).


Conflicts of Interest

In order to perform his/her duties with honesty and fairness and in the best interest of Jubilant, all team members must avoid conflicts of interest in their employment. A conflict of interest may occur if outside activities or personal interests influence or appear to influence your ability to make objective decisions in the course of you job responsibilities. Conflicts of interest may arise from soliciting or accepting gifts and/or excessive entertainment or gratuities from any person or entity that does, or is seeking to do, business with Jubilant.

It is important for team members to advise their supervisor of any conflicts of interest they observe, so that timely corrective action can be taken to resolve the issue(s).


Prohibited Activities with Customers and Vendors

Employees will not engage in any activities that involve illegal payments of cash or other items of value, or receive payments of cash or other items of value, for patient referrals, patient inducements or in return for purchases or leases or recommendations to purchase or lease any supplies, equipment or services from Jubilant or by Jubilant. No entertainment of Jubilant Clients or their representatives may exceed the expenditure limits contained in the Jubilant Travel & Entertainment Policy and Procedure. Violation of these entertainment limits shall result in no reimbursement of these expenditures and/or discipline of the employee involved, up to possible termination of such employee's employment with Jubilant.

Employees will not engage in any form of anti-competitive behavior or “price fixing” with competitors or any other individuals or organizations.

It is important for team members to advise their supervisor of any prohibited relationships with customers or vendors that they observe, so that timely corrective action can be taken to resolve the issue(s).


Privacy and Confidentiality

During the course of his/her duties as an employee of Jubilant, team members will have access to information that is confidential and/or proprietary to Jubilant and the patients that Jubilant serves. All patient information is regarded as confidential and each patient is entitled to protection of that information. Jubilant will respect each patient’s right to privacy and security of their protected health information (“PHI”) and shall comply with all of the requirements of the Health Insurance Portability and Accountability Act and all related, applicable regulations (“HIPAA”). Other proprietary Jubilant information may not be used or disclosed outside the context of each team member’s duties and functions, in his/her service to Jubilant.

It is important for team members to advise their supervisor of any inappropriate disclosure of PHI or confidential Jubilant information, so that timely corrective action can be taken to resolve the issue(s).


Billing and Credit Balances

Jubilant shall ensure that all billings are true, accurate and conform to applicable Client Provider Agreements and all applicable Federal and state laws and regulations. Each team member of Jubilant shall use their best efforts to prohibit any team member or agent of Jubilant from knowingly presenting or causing to be presented claims for payment or approval that are false, fictitious or fraudulent. If a billing error or any error related to a Jubilant Provider Agreement is detected, immediate notification of your supervisor is mandatory. If the situation is not resolved in a timely fashion, the matter shall immediately be reported to the Jubilant Compliance Hotline so that the Chief Compliance Officer of Jubilant can investigate the matter and intervene, if necessary. Jubilant shall comply with all applicable Federal and state laws and regulations governing credit balance reporting and refund(s) of all overpayments in a timely manner.

It is important for team members to advise their supervisor of any improper billing and/or credit balance situations that they observe, so that timely corrective action can be taken to resolve the issue(s).


Reporting of Noncompliance

If an area of potential noncompliance is discovered, each Jubilant Team Member shall report this to his or her immediate supervisor. If the team member is not comfortable with reporting noncompliance with his or her immediate supervisor, he or she has three approved alternate courses of action, as follows;

  1. He or she may follow the Communication and Resolving Problems section in the Jubilant Team Member Handbook; or,
  2. He or she may report the matter to the Jubilant Chief Compliance Officer; or,
  3. He or she may access the Jubilant Compliance Hotline via telephone or email.

These reports will be kept confidential and shared only on a bona fide need-to-know basis. Jubilant will take no adverse action against team members reporting noncompliance, whether or not they ultimately prove to be well founded, as long as they are submitted in good faith and without malicious intent.