Code of Conduct and Ethics

Business Ethics and Compliance

Labcorp is committed to uncompromising integrity in all that we do and how we relate to each other, our patients, customers, suppliers and vendors, and the communities in which we operate and provide services.

Our culture of integrity and compliance has permeated our operations throughout our 51-plus year history, and will continue to do so into the future. Labcorp is subject to and must comply with a broad range of regulations within the United States, as well as in the global markets in which we operate. Our compliance program focuses particularly on regulations related to health care fraud and abuse, anti-kickback, physician self-referral, government reimbursement, anti-bribery/anti-corruption, anti-human trafficking and trade sanctions.

Our Company

Our Longstanding, Global Compliance Program Is Designed To:

1. Promote honest and ethical conduct
2. Address compliance with applicable governmental laws, rules and regulations
3. Deter wrongdoing
4. Foster full, fair, accurate and timely disclosure of concerns or violations

Labcorp designates a Chief Compliance Officer who reports to the Chief Executive Officer. In addition, the Senior Vice President, Compliance, the corporate compliance department, and the Labcorp Compliance Committee assist the Chief Compliance Officer with the implementation and administration of the Labcorp compliance program. The Chief Compliance Officer reports regularly to the Quality and Compliance Committee of our Board of Directors.

Labcorp’s corporate compliance department partners with our business teams to advance delivery of world-class services and innovation with integrity by promoting practices that comply with laws, regulations and high ethical standards. The corporate compliance department supports Labcorp by proactively identifying, assessing and remediating risks, as well as by fostering a culture of commitment to compliance and accountability among all employees.

The foundation of an effective compliance program includes clear, understandable and easily accessible written policies and guidelines. Our Code of Conduct and Ethics outlines the compliance principles and standards to which every employee, officer and director, as well as our agents, representatives, consultants, vendors and contractors must fully commit. The document is translated into 14 languages and is provided to all employees as well as posted on our public website. Please review our Code of Conduct and Ethics by clicking here.

To further guide our business practices in alignment with the principles set forth in the Code of Conduct and Ethics, Labcorp maintains the Business Practices Manual, which contains 25 policies on a variety of topics including health care fraud and abuse, anti-corruption, international trade, client and third-party expenses, privacy, insider trading, conflicts of interest, ethical labor and the Labcorp Action Line. These policies are also available in multiple languages to all employees.

Included in our Business Practices Manual is the Anti-Bribery and Anti-Corruption Policy, which sets forth Labcorp’s commitment to prohibit bribery and improper payments in all forms and provides guidance on how to identify red flags and report suspicious activities. We recognize that intermediaries pose a heightened corruption and bribery risk. As a result, we implemented a rigorous due diligence process to review the entities and individuals engaged to interact with government officials on Labcorp’s behalf. Please review our Anti-Bribery and Anti-Corruption policy here.

Reporting and Investigations: Labcorp’s Speak Up! Culture

Our employees play an important role in maintaining an active compliance culture and are encouraged to proactively “speak up,” ask questions and report concerns in a timely manner. All employees are responsible for reporting any actual or suspected violations of Labcorp’s Code of Conduct and Ethics, company policies, and any applicable laws or regulations in a proactive manner and without delay.

We urge employees with a question or concern to first speak to their manager or supervisor, or to seek help from Labcorp resources within the Corporate Compliance, Human Resources, Internal Audit or Law Departments. Labcorp also offers an Action Line as an alternative platform for reporting confidentially and/or anonymously. The Labcorp Action Line is operated by an independent third-party vendor using a platform to receive reports through an online portal and call center, which is available 24/7, 365 days a year and provides interpreter support in more than 150 languages.

Labcorp treats every report seriously and takes appropriate action, including investigation, discipline, training and enhancement of our policies and processes. We do not tolerate retaliation of any kind (whether direct or indirect) against anyone who has in good faith reported an actual or suspected violation.

Risk Assessment, Audits and Monitoring

Risk assessments are an integral part of process improvement and to identify and prioritize healthcare compliance and anti-corruption risks. Labcorp conducts annual risk assessments at a global and regional level. Our corporate compliance department has a designated audit team that develops and executes an annual audit plan, and additional audit reviews are conducted by Internal Audit. Results from risk assessments and auditing are reported to relevant stakeholders, and remediation plans are completed and tracked in a timely manner.

Supplier Code of Conduct

Given Labcorp’s global reach and the healthcare system’s reliance on our services, including the ability to transport sensitive information and medical specimens, we take great effort to maintain our robust supply chain operations through global supplier networks.

Our Supplier Code of Conduct covers the entire Labcorp business worldwide, creating one common Supplier Sustainability Program (SSP) across the global business.

The Labcorp Supplier Sustainability Governance Committee is responsible for implementing and providing oversight for the SSP. Strategic suppliers are expected to foster and acknowledge the principles of the Code of Conduct, and responsible Labcorp employees receive rigorous training in the application of the SSP.

Strategic suppliers are expected to:

Conduct business in accordance with the highest ethical standards and act with integrity
Uphold the human rights of their workers and treat them with respect and dignity
Provide safe working conditions and a healthy work environment
Implement management systems to facilitate compliance with applicable laws and company policies

Even amidst a global pandemic that caused great delays in many healthcare and non-healthcare supply chains, we are proud to report that our supply chain continued to operate and scale to accommodate new demand.

Our supplier network makes us one of the largest transporters of goods in the world, and our Supplier Code of Conduct assures all suppliers are aware of the expectation to operate with integrity, reliability and efficiency.

Supplier Oversight and Diversity Program

Labcorp has developed a Supplier Code of Conduct that outlines our requirements for suppliers to conduct business ethically, responsibly and with integrity. Labcorp requires all suppliers to register on our supplier portal, which tracks each supplier across our operations. This increased attention to Supplier Code of Conduct, and the registration of each supplier, allows for efficient and transparent monitoring of each supplier.

We make significant efforts to use small business vendors, suppliers and subcontractors whenever possible, and Labcorp has an active small business purchasing program. Labcorp conducted business with approximately 500 suppliers that are small enterprises owned by minorities, women, veterans, disabled individuals or the economically disadvantaged in 2021. Labcorp includes minority, women and veteran business enterprise suppliers in our bidding process where applicable.

We are also developing processes to support supplier partners who represent diverse or underserved communities.

Third-Party Risk Management (TPRM)

Health care risks are expanding and requiring more effort to manage. Recognizing that, Labcorp created an enterprise-wide approach to third-party risk management. Having an effective TPRM program directly impacts our ability to grow, innovate and fulfill our mission.

Deployed in 2021, this approach featured:

Implementation of a central common enterprise third-party risk management program
Centralization of processes for third-party risk assessments relating to cyber risk, compliance (anti-human trafficking and foreign third-party), and data privacy, notably the U. S. Health Insurance Portability and Accountability Act (HIPAA) and Protected Health Information
Creation of a charter, policy and standard operating procedure
Design of scalable processes to allow for future expansion of the intake and gating process to other risk domain areas such as resilience and Environment, Social and Governance

This Enterprise TPRM program addresses the first two stages of the relationship lifecycle (planning/strategy and TPR assessment). In 2022 and beyond, Labcorp will evolve this program to address the remaining three stages: contracting, ongoing monitoring/management and periodic reevaluation.

Promoting Fundamental Human Rights

We have a responsibility to do our part to address issues such as human trafficking and others that exploit human beings. Labcorp has policies, procedures and training in place to help avoid, detect and address issues of modern slavery (human trafficking, forced labor, unlawful child labor and commercial sexual exploitation) and other unethical or illegal labor practices by our employees, agents and subcontractors or those anywhere in our supply chain.

Labcorp recognizes the importance of maintaining and promoting fundamental human rights in our operations and throughout our supply chain. Derived from the principles and guidance of the United Nations, the International Labor Organization and the Organization for Economic Cooperation and Development, we operate under programs and policies that:

Provide fair and equitable wages, benefits and other conditions of employment in accordance with local laws
Recognize employees’ right to freedom of association
Provide humane and safe working conditions
Support a work environment that is free from human and sexual trafficking, forced and bonded labor, and unlawful child labor
Promote a workplace free of discrimination and harassment
Address the human rights and environmental issues connected with the mining and trading of conflict minerals

Commitment to Ethical Labor Practices

Our company has policies, procedures and training in place to help avoid, detect and address any unethical or illegal labor practices by our employees, agents and vendors or those anywhere in our supply chain.

To view all previously filed Combating Modern Slavery Statements and the Labcorp Ethical Labor and Anti-Human Trafficking Policy, please visit here.