Code of Conduct

Our Commitment to You

At Clever Care Health Plan, we believe that trust is the foundation of everything we do. This Code of Conduct reflects our promise to conduct business with the highest ethical standards and in full compliance with federal and state laws.

We share this Code publicly because we want you—our members, providers, partners, and communities—to know what we stand for and how we hold ourselves accountable. It guides how we work with everyone we serve and demonstrates our commitment to doing the right thing, every day.

Our Mission, Vision, and Values

Our Mission

To deliver personalized, culturally attuned health care that empowers members to take an active role in achieving better health, grounded in compassion, respect, equity, and integrity.

Our Vision

To be the most trusted Medicare Advantage plan for diverse communities, known for equitable access, exceptional service, and better health outcomes.

Our Values

Diversity
We embrace cultural differences and design equitable services that reflect the communities we serve.

Innovation
We improve continuously through data, technology, and new approaches to care delivery.

Empathy
We treat every interaction with dignity, patience, and understanding.

Integrity
We consistently honor our commitments and act responsibly with the trust placed in us by our members and communities.

Collaboration
We partner internally and externally to solve complex health challenges.

Stewardship
We manage financial, clinical, and community resources with discipline and a deep sense of responsibility.

What We Expect From Our Team

All Employees

Every member of the Clever Care team is expected to:

• Comply with this Code, related policies, and all applicable laws
• Complete required training on time, including ethics, privacy, information protection, and compliance
• Use this Code, related policies, and the law as a guide in all business activities
• Exercise good judgment and avoid even the appearance of improper behavior
• Seek advice when questions arise about this Code, applicable laws, or uncertain situations
• Speak up about possible violations of this Code, Clever Care policy, or the law

Managers and Leaders

Those in leadership roles have additional responsibilities to:

• Promote a culture of ethics and compliance
• Model appropriate conduct
• Ensure their teams understand their responsibilities under this Code
• Create an environment where employees feel comfortable raising concerns
• Consider adherence to this Code when evaluating performance
• Never encourage achieving business results at the expense of ethical conduct
• Act promptly to prevent violations

How We Protect Your Information

We take the privacy and security of personal information seriously. Protecting your information is not just a legal requirement—it reflects our deep respect for the trust you place in us.

Our Commitment

• We safeguard personal information and use or share it only as authorized or required by law
• We train our employees on the proper handling of sensitive information
• We use only the minimum information necessary to provide services
• We maintain secure systems appropriate to the sensitivity of the information

What This Means for You

• Your health information is protected under HIPAA and other applicable laws
• We will not share your information with anyone not involved in your care unless we have your authorization or are required by law
• We have systems in place to prevent unauthorized access to your information
• If you ever have questions about what information we collect and how we use it, you can request our Notice of Privacy Practices

If you believe your information has been improperly accessed or disclosed, please contact us immediately. We take all reports seriously and investigate thoroughly.

Maintaining Accurate Records

Accurate and reliable records are essential to serving our members well and meeting our legal and regulatory obligations. Clever Care is committed to:

• Maintaining truthful, complete, and accurate records of all business transactions
• Ensuring all financial records provide a clear and auditable account of our activities
• Preparing all reports, claims, and member records with care and honesty
• Responding to regulatory requests accurately and on time

We never alter, withhold, or destroy records related to any investigation, and we cooperate fully with all regulatory inquiries.

Avoiding Conflicts of Interest

A conflict of interest occurs when personal interests could interfere—or appear to interfere—with someone’s ability to make fair business decisions. At Clever Care, we expect all employees to:

• Avoid situations where personal gain could influence professional judgment
• Disclose any potential conflicts of interest
• Refrain from using company resources or information for personal benefit

We require annual conflict of interest disclosures to help ensure transparency and protect the trust our members and partners place in us.

Gifts and Business Courtesies

We conduct business with honesty, integrity, and fairness. To protect against even the appearance of improper influence:

• Employees may not accept gifts valued at $25 or more from vendors, customers, or business partners
• We have a zero-tolerance policy for bribery
• We comply with all applicable laws regarding gifts and business courtesies, including the Anti-Kickback Statute

Medicare Marketing Guidelines

When interacting with Medicare beneficiaries, we follow strict CMS guidelines:

• Nominal gifts cannot exceed $15 per item or $75 total per person per year
• We do not offer cash or gift cards that could be considered cash equivalents
• We provide only light refreshments—not meals—at marketing events
• We do not cold call, text, or use door-to-door solicitation to contact prospective members

These guidelines help ensure that your decision to join Clever Care is based on what is best for your health care needs—not on incentives.

Preventing Fraud, Waste, and Abuse

Clever Care is committed to preventing, detecting, and correcting fraud, waste, and abuse in health care. These issues directly impact our members, providers, and the Medicare program.

What This Means

Fraud is intentional deception made to gain an unauthorized benefit.

Waste is the overuse or misuse of resources that leads to unnecessary costs.

Abuse includes practices inconsistent with sound medical, business, or fiscal standards.

Our Commitment

• We investigate all reports of potential fraud, waste, or abuse
• We do not tolerate retaliation against anyone who reports concerns in good faith
• We work closely with government agencies to protect program integrity

Reporting Concerns

If you suspect fraud, waste, or abuse—whether by a provider, employee, or anyone else—we encourage you to report it. You can contact us confidentially, and anonymous reporting is available.

Accurate Billing and Claims

We are committed to billing practices that are honest, accurate, and compliant with all laws and regulations.

• We only submit claims for services that are medically necessary and properly documented
• We do not knowingly submit false or misleading claims
• We train our staff on proper billing procedures

False claims are a serious matter. The Federal False Claims Act and state laws impose significant penalties for fraudulent billing, and we take every allegation seriously.

Fair Competition

Clever Care believes in competing fairly and honestly. We comply with all antitrust laws designed to promote healthy competition in the marketplace.

• We do not engage in price-fixing or market allocation with competitors
• We do not share confidential competitive information
• All bids and proposals are accurate, complete, and responsive

Fair competition benefits everyone—especially the members and communities we serve.

Responsible Use of Resources

We manage company resources responsibly and expect all employees to do the same. This includes:

• Using company equipment, systems, and supplies for business purposes
• Protecting intellectual property and confidential information
• Maintaining appropriate boundaries between personal and professional activities

Employees have no expectation of privacy when using company systems, and all company information is subject to monitoring.

Equal Opportunity and Respectful Workplace

Clever Care is committed to creating a workplace—and a member experience—built on dignity, respect, and inclusion.

Equal Employment Opportunity

We provide equal employment opportunity without regard to race, religion, sex, national origin, age, genetic information, disability, veteran status, sexual orientation, gender identity, or any other protected characteristic.

Preventing Harassment

We do not tolerate harassment of any kind—whether in our offices, at company events, or in digital communications. Every person deserves to be treated with respect.

Safe Environment

We maintain a safe, healthy, and substance-free work environment. We do not tolerate violence, threats, or any conduct that puts others at risk.

Social Media and Digital Communications

In today’s connected world, what we say online matters. Clever Care employees are expected to:

• Clearly distinguish personal opinions from company positions
• Never share confidential member, provider, or company information online
• Comply with all CMS marketing and communication rules when engaging with prospective or current members
• Avoid conduct that could harm Clever Care’s reputation or violate our values

We monitor company systems and take violations seriously.

Responsible Use of Artificial Intelligence

Artificial intelligence and automated tools can improve how we work—when used responsibly. At Clever Care:

• AI tools may only be used for approved business purposes
• Protected health information and confidential data may not be entered into public or unapproved AI systems
• All AI-generated content must be reviewed and validated before use
• AI supports—but does not replace—human judgment in clinical and coverage decisions

We are committed to using technology in ways that protect our members and uphold our values of integrity and transparency.

How to Report a Concern

We want to hear from you. If you have concerns about potential violations of this Code, fraud, waste, abuse, or any other ethical issue, we encourage you to speak up.

Contact Us

Compliance Hotline
1-833-217-8644

Fraud, Waste, and Abuse Hotline
1-833-217-8645

Email
compliance@ccmapd.com
fraudwasteabuse@ccmapd.com

Our Promise

• Reports may be made anonymously
• We investigate all concerns thoroughly
• We do not tolerate retaliation against anyone who reports a concern in good faith

Your voice helps us maintain the trust and integrity that are central to who we are.

Questions?

If you have questions about this Code of Conduct or how Clever Care upholds its commitment to ethical business practices, please reach out to us. We are here to help.

Member Services Hours

• October 1 to March 31: 8 am to 8 pm, seven days a week
• April 1 to September 30: 8 am to 8 pm, weekdays

Visit Us
You are always welcome at one of our community centers:

• Koreatown Community Center: 928 South Western Avenue, Suite 227, Los Angeles, CA 90006
• Westminster Community Center: 9600 Bolsa Avenue, Suite D + I, Westminster, CA 92683
• Monterey Park Community Center: 117 West Garvey Avenue, Suite C, Monterey Park, CA 91754

We offer support in the language you need. Just let us know how we can best assist you.

Clever Care Health Plan is committed to conducting business with integrity and transparency. This Code of Conduct reflects our values and our promise to the members and communities we serve.