Code of Conduct for All State Compensation Insurance Fund Workforce Members 2021
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Code of Conduct for All State Compensation Insurance Fund Workforce Members
Code of Conduct
for All State Compensation Insurance Fund
Workforce Members
2021
Page 1 | ©2021 State Compensation Insurance Fund
Code of Conduct for All State Compensation Insurance Fund Workforce Members
TABLE OF CONTENTS
MESSAGE FROM VERNON STEINER, HOW I MAINTAIN A SAFE AND HOW I USE RESOURCES RESPONSIBLY 20
PRESIDENT AND CEO 3 HEALTHY ENVIRONMENT 12 Using State Fund Resources 20
OUR CODE OF CONDUCT 4 Working in a Safe and Healthy Environment 12 Using State Fund Information Systems 21
Being a Responsible Member of Protecting and Respecting Information 21
STATE FUND’S VISION, PURPOSE, AND the Workforce 12
CORE VALUES 4 What is Personal Information? 21
Making our Workplace Equal and Diverse 12
Governing State Fund 5 Respecting the Works of State Fund
Prohibiting Harassment or Discriminatory and Others 22
Maintaining Trust and Credibility 5 Conduct 13
Retaliation Is Prohibited and Not Tolerated 14 HOW I DO MY PART TO KEEP
REVIEWING IMPORTANT POINTS CALIFORNIA WORKING 23
OF THE CODE 6 Reporting Complaints 14
Sharing Your Ideas 23
HOW I DO WHAT IS RIGHT 7 Threats and Domestic and Workplace
Violence 14 Transparency — California Public
Being Ethical & Doing the Right Thing 7 Records Act 23
Imminent Danger Threats in the Workplace 15
Ethics Decision Tree 7 Transparency — Bagley-Keene Open
Substance Abuse-Free Workplace 15 Meeting Act 23
Voicing Your Legal, Ethical, or
Privacy Concerns 8 Employee Assistance Program 15 Workers’ Compensation Fraud 23
Professional Codes of Ethics or Rules 8 HOW I REPRESENT STATE FUND 16 ACKNOWLEDGING AND SUPPORTING
Improper Activities — The California Functions Involving Alcohol 16 THE CODE AND RELATED POLICIES 24
Whistleblower Protection Act 9
Financial Disclosures and the Statement of APPENDIX - RESOURCES 25
Complying with Our Corporate Policies 9 Economic Interests – Form 700 (SEI) 16
Your Corporate Policy Compliance
Gifts 17
Obligations 9
Personal Interest Disqualification 18
Avoiding Incompatible Activities 10
When to Disqualify Yourself from
Outside (non-State Fund) Work by
Decision-Making or Contracting 18
Workforce Members 10
Reporting Failures to Disqualify 19
Gambling 11
Upholding the Law 19
Monetary Loans 11
Page 2 | © 2021 State Compensation Insurance Fund
Code of Conduct for All State Compensation Insurance Fund Workforce Members
MESSAGE FROM VERNON STEINER, PRESIDENT AND CEO
Dear State Fund Team,
Doing the right thing isn’t always simple, easy, or clear. But doing the right thing is part of who
we are—it’s one of our core values and it’s central to our goal of making worker’s compensation
work in California.
Our Code of Conduct is one of the tools we use to help us determine right from wrong. It aligns
closely with all of our core values and is an extension of who we are and a critical piece of the
culture we are continuing to build. The Code also helps us maintain the trust we’ve built with
our policyholders, brokers, injured workers, medical providers, and regulators—as well as with
each other.
The 2020 Code of Conduct revisions include:
y Callouts highlighting your most-queried topics
y Definitions of our four updated core values
y Updated language regarding diversity
Please familiarize yourself with the redesigned code as soon as you have an opportunity. By
working together and holding each other accountable, we can ensure State Fund continues to
be an honest and ethical organization.
Sincerely,
Vernon Steiner
President and CEO
Page 3 | ©2021 State Compensation Insurance Fund
Code of Conduct for All State Compensation Insurance Fund Workforce Members
OUR CODE OF STATE FUND’S VISION, PURPOSE,
CONDUCT AND CORE VALUES
VISION
1 2 To become California’s workers’ compensation carrier of choice.
Guides you to
make honest, ethical,
and right decisions
PURPOSE
at work. State Fund’s purpose is to provide fairly priced workers’ compensation insurance,
help make workplaces safe, and restore injured workers.
CORE VALUES
3 4 Our core values are the guiding force for our culture and the quality of service we
provide to our internal and external customers. State Fund is updating our core
Shows everyone Is a living document values to demonstrate our commitment to fulfilling our purpose and reflecting
State Fund’s to use in your the culture fostered at State Fund.
commitment to be everyday work.
y Respect Everyone – Create an environment where all people and perspectives
an honest, legally
compliant, and are valued and teams work together to serve the diverse needs of California
responsible company. businesses.
y Show We Care – Listen to understand and invest the time and resources needed
to help California employers and injured workers.
y Do What’s Right – Approach every situation with a passion to help, a desire to
learn and a commitment to integrity – because doing the right thing isn’t always
simple, easy, or clear.
y Be Innovative – Seek out solutions and consider new approaches to serve our
customers and help improve California’s workers’ compensation system.
Page 4 | ©2021 State Compensation Insurance Fund
Code of Conduct for All State Compensation Insurance Fund Workforce Members
STATE FUND’S VISION, PURPOSE, AND CORE VALUES
Governing State Fund The Board has full power, authority, and Maintaining Trust and Credibility
jurisdiction over State Fund to perform the
State Fund rests on a solid business foundation State Fund’s success depends on people
actions necessary to meet these goals.
where our leaders value our policies and trusting and having confidence in us. When
procedures and are accountable for what they Oversight is achieved through the Board of we do what we say we will do with honesty,
do. State Fund Governance provides the set of Director meetings and committees, State integrity, and honor, we gain the trust of the
laws, policies, and procedures used to run our Fund’s officers, and other members of the public, our customers, and our employees. How
business. Executive Committee. Consistent with good successful we are as a company depends on
corporate governance, the Board has delegated keeping our commitments and acting honestly
The Board of Directors (Board) provides
authority to the President to allow him to to reach our goals.
leadership to State Fund that is consistent with
administer, manage, and conduct the day-to-
our purpose and core values, management It is easy to set out rules at State Fund, but the
day business and affairs of State Fund.
philosophy, investment policy, and regulatory proof lies in how you act every day at work.
requirements. For the Code of Conduct, the Board: People will evaluate us on how we conduct our
y Authorizes having a Code of Conduct. day-to-day business.
The Board leads us to ensure that State Fund
operates in a manner that is y Reviews and approves Code revisions. You must treat your job at State Fund as a
public trust. To do that, you must avoid conflicts
y Approves and supports the Code’s final
of interest and provide a good example of public
content.
service. When you make it a practice to think
F y Approves material changes to Corporate
L RE INA about and bring up your ideas to improve State
GA SP Policies supporting the Code. Fund or your concerns about ethical conduct,
NC NSIB
LE
you carry out your duty as a public servant and
O
IAL LE
help State Fund reflect its core values.
LY
RESP
S OC ON
LL
IA S
L
IB Y
A
C
LE HI
ET
Page 5 | ©2021 State Compensation Insurance Fund
Code of Conduct for All State Compensation Insurance Fund Workforce Members
REVIEWING IMPORTANT POINTS OF THE CODE
You and State Fund earn the trust of our
customers and the public by making good
choices and acting ethically and honestly.
Learning and following State Fund’s core values
and standards is part of your job.
Sharing your ideas about how to make State
Fund better and reach its goals should be part
of your everyday work.
When in doubt, ask for help. If you have ideas,
questions, wish to discuss an issue, or want to
report a possible violation, talk to your manager,
or contact AskAdmin. See the “Appendix -
Resources” on page 25 for more resources.
If you wish to raise concerns or questions, you
may also report anonymously by contacting the
Ethics and Privacy Hotline.
You play a vital role at State Fund. Your choices
and ideas can make State Fund a better place
to work.
Page 6 | ©2021 State Compensation Insurance Fund
Code of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I DO WHAT IS RIGHT
Being Ethical & Doing the It is vital for the public and our stakeholders to
Right Thing trust the work we do at State Fund. Your drive
to problem solve, make wise decisions, and your
State Fund trusts you to show the highest desire to do the right thing when doing your job
standards of ethical and professional conduct creates this trust.
and personal integrity when doing your job.
When you make good choices that uphold our At work, you must have the courage to tackle
core values, you make a difference. tough decisions and make difficult choices. You
can feel assured that State Fund supports your
State Fund is dedicated to ethical, fair, and decisions when you act in good faith. Be fair
responsible competition. We do not improperly in what you do, considering how others may
cooperate or coordinate activities with our perceive your actions. At times you may have to
competitors. We do not violate our ethical do more than simply what the law requires.
standards to get a certain business result. We
also do not engage or help in unlawful boycotts Use our Decision Tree to help you make wise
of customers. and ethical decisions.
Ethics Decision Tree
If you’re unsure of your decision, ask yourself these four questions:
YES TO
ALL.
You can take action
in good faith.
ONE TWO THREE FOUR
Does it comply with Does it support State Fund Is it legal? Does it support NO TO
ANY.
I follow the Code in my daily work, which gives State Fund policy? values? Respect everyone; the best interest of
Show we care; Do what is our stakeholders?
Stop! This may have
me a foundation to make the right choices every right; Be innovative.
serious results.
day. I know that our success depends upon our
customers having confidence in us to act with
NOT
SURE?
integrity and do the right thing.
Seek help before
acting further.
Page 7 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I DO WHAT IS RIGHT
Voicing Your Legal, Ethical, or
IMPORTANT NUMBERS
Privacy Concerns
Human Resources (800) 499-8668
We provide you with a “safe landing
spot” if you wish to raise concerns. Privacy Office (888) 724-3237
If you think an action may violate the law, Independent Ethics and
State Fund’s standards for ethics and core Privacy Hotline (888) 254-4301
values, or policies, you have a responsibility to
tell someone. You can reach out to a variety of
resources for assistance. If you feel uncomfortable using these channels,
you can report to our independent Ethics and
State Fund encourages you to seek advice with
Privacy Hotline by calling (888) 254-4301 or by
supervisors or managers. You can also contact
submitting your question or concern online.
Human Resources in the following ways:
You can also report anonymously, if you choose.
y Email Human Resources at ethics@scif.com
Professional Codes of Ethics or Rules
y Contact online at AskAdmin, If you have a role such as attorney, accountant,
y Call Human Resources at (800) 499-8668. internal auditor, medical professional,
For privacy matters, including reporting compliance professional, procurement, or
suspected privacy incidents, email the project management professional, you must
Privacy Office at PrivacyOffice@scif.com or follow codes of behavior for your profession.
call (888) 724-3237. You must follow State Fund’s Code of Conduct
in addition to other professional codes, if they
Asking questions and raising concerns to apply to you.
improve State Fund helps uphold our integrity.
It is important that you do not view actions as
acting against your co-workers, managers,
or department.
Page 8 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I DO WHAT IS RIGHT
Improper Activities — The California Complying with Our
Whistleblower Protection Act Corporate Policies
The California Whistleblower Protection Act Corporate Policies set State Fund’s standards for
prohibits retaliation for reporting improper doing the right thing and for our success. They
activities. In California, whistleblower protection assure that our business practices line up with
includes protection of your identity (except our vision, core values, and purpose.
from law enforcement) and your right to be free
Your Corporate Policy Compliance
from retaliation for reporting.
Obligations
You may report improper activities such as To make State Fund a successful work
theft, fraud, incompatible activities, misuse environment, you must consistently follow
or abuse of state property, gross misconduct, State Fund Corporate Policies and Corporate
and incompetence or inefficiencies by Procedures. Following them furthers the best
State of California employees. You can find interests of State Fund, our workforce, and
Whistleblower Notices where other workforce our stakeholders.
notices are posted.
In your role, you should read, understand, and
To file a complaint, you can contact the follow our Corporate Policies and Corporate
California State Auditor by calling the toll- Procedures that deal with your work role. If you
free Whistleblower Hotline at (800) 952-5665, have any questions, ask for help and advice.
submitting your report online, or sending your
complaint by mail. The Act protects a reporting If you fail to follow our Corporate Policies and
person’s identity unless a law enforcement Procedures, you may be subject to disciplinary
agency needs it to conduct a criminal action up to and including termination, as
investigation. allowed under the California Government Code.
You may report retaliation for having reported
improper activities to the State Personnel
Board.
Page 9 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I DO WHAT IS RIGHT
Avoiding Incompatible Activities Click or tap the questions Q below to see the answers A . Outside (non-State Fund) Work by
Workforce Members
State Fund’s Incompatible Activities Statement
Policy prohibits Workforce members from I have a brother and sister who work You may wish to take on outside work with
Q companies that are not our competitors,
taking part in actions contrary to their California in the same department as I do. We
civil service and State Fund employment. Our each work for different supervisors. customers, or suppliers. You may wish to accept
Policy aligns with the California Government Is this a problem for me? a voluntary, elected, or appointed position with
Code and Labor Code. a political entity. Outside work in itself is not an
incompatible activity. However, you must keep
There are special provisions of the California your second job strictly separate from your
Insurance Code (Cal. Ins. Code § 11770(f)) that State Fund job. If you are considering working
apply to the Board that may supersede some at a job in addition to State Fund, contact
provisions of the Government Code. Employee Relations, in writing and get approval
State Fund’s Incompatible Activities Statement before you start the outside work.
Policy requires you notify Employee Relations y You may not do outside work on State Fund
before doing certain acts, including but not Q My nephew applied for and was
chosen for a vacant position in my time, on State Fund premises, or with State
limited to: Fund resources.
unit. My nephew will be reporting to
y Doing any type of work contrary to the one of my subordinate supervisors. y You must not market or sell products or
business interests of State Fund, such as Is this a problem for me? services to State Fund from the business
taking a job with a competitor, supplier, or entity related to your outside job.
contractor that may influence the decisions
y Your outside work must not interfere with
you make in your State Fund job or
or keep you from giving the time and effort
y Receiving any gift or service from anyone needed to fulfill your duties as a State Fund
except the State related to performing your Workforce member.
State Fund job or
y Serving as a board member for a company
or organization that competes with State
Fund or
y Hiring or supervising a close family member
at State Fund.
Page 10 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I DO WHAT IS RIGHT
Click or tap the questions Q below to see the answers A .
Q I’d like to use my law license to Monetary Loans
perform part-time legal services. It is an inappropriate use of your State
I am thinking of working as a part Can I do this? Fund position as a supervisor, manager,
Q
time sales representative for a life or senior leader to request or accept loans
insurance company. Can I accept the from subordinates or other members of the
job and still work for State Fund? Workforce under your influence or control.
Monetary loans between co-workers are
personal, private matters and not the
responsibility of State Fund. Employees are
under no obligation to lend money to co-
workers. If you do enter into this type of
transaction, you do so at your own risk.
Gambling
You may not gamble on State Fund premises.
Q I’ve been offered part-time work in
a collection agency. Can I accept the Gambling is any game of chance, contest,
job and still work for State Fund? sweepstakes, or other form of gaming
prohibited by the California Penal Code and
California Business and Professions Code.
Gambling activities include, but are not limited
to gaming, lotteries, raffles, office pools, online
betting, or where money is exchanged for a
chance to win a prize.
Page 11 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I MAINTAIN A SAFE AND HEALTHY ENVIRONMENT
Working in a Safe and Healthy y Promptly and correctly, address ethical
Environment concerns raised by Workforce members.
Avoid viewing ethical concerns as threats or
State Fund is committed to making the challenges to authority.
workplace safe. You must follow Health and
y Encourage ethical dialogue as a natural part
Safety Corporate Policies and Procedures. You
of your daily work.
must report potential safety hazards or threats
of violence.
Making our Workplace Equal
Being a Responsible Member of and Diverse
the Workforce State Fund is committed to promoting a culture
that values equality, diversity and inclusion.
You are a vital part of State Fund. You make
You and each member of our Workforce
State Fund a better place to work by treating
provide a unique viewpoint and input to
others with respect and dignity. We trust you
State Fund. A diverse and inclusive Workforce
will avoid exaggeration, insulting remarks, or
makes a more productive and fulfilling work
improper descriptions of people and other
environment for all. You and all persons who
companies. When you act fairly, ethically, and
apply for work at State Fund are given equal
responsibly at work, you reflect State Fund’s
employment opportunity and a workplace free
core values.
from discrimination and harassment based
If you are a manager, you must: on a protected class, sexual harassment, and
retaliation.
y Create a workplace which values doing
the right thing. In any business, ethical
behavior does not simply happen. It starts
with the tone at the top. Leaders model by
I treat my colleagues with respect and dignity example and communicate clear and direct
and help create an environment where all people
expectations for action.
and perspectives are valued. Teamwork and
collaboration make us stronger, more innovative,
and better able to deliver on our commitment to
California businesses.
Page 12 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I MAINTAIN A SAFE AND HEALTHY ENVIRONMENT
Prohibiting Harassment or
Discriminatory Conduct
State Fund prohibits and does not tolerate sexual
harassment, discrimination, or any harassment
against a person due to membership in or
association with a protected group. In addition,
these practices are unlawful under state and
federal law.
You will not be discriminated against or harassed
based on protected group status. Such status
includes, but is not limited to:
y race
y color
y religion or religious creed
y national origin (including citizenship and
ancestry)
y physical disability (including HIV and AIDS)
y mental disability, medical condition (including
cancer and genetic characteristics or
information)
y denial of Family Medical Care Leave
y pregnancy
y marital status
y sex (sexual orientation, transgender status)
y gender (including pregnancy, childbirth,
breastfeeding, and related medical conditions)
y identity and expression
y age (over 40)
Page 13 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I MAINTAIN A SAFE AND HEALTHY ENVIRONMENT
y political affiliation and State Fund employees found to have engaged Threats and Domestic and
y military or veteran status. in discrimination, harassment, sexual Workplace Violence
harassment, or retaliation at State Fund or at
Workforce members who believe they have State Fund-organized activities outside the State Fund will not tolerate violence or
been subjected to discrimination or harassment workplace will be subject to disciplinary action, threatening behavior.
based on any protected group status, or to up to and including termination. State Fund You must report all threats or acts of violence,
sexual harassment may file a complaint. commits to take all steps necessary to prevent including domestic violence, directed at State
State Fund’s harassment-free workplace and correct discrimination, harassment, sexual Fund’s Workforce and/or property that may
policy extends to others whom our workforce harassment, and retaliation in the workplace. impact the workplace to the Threat Evaluation
may interact with, such as outside vendors,
Team. The Threat Evaluation Team evaluates
customers, professionals, job applicants, and Reporting Complaints and responds to all reported threats or acts of
other providers of goods or services to any State
You may report discrimination, harassment, violence.
Fund workplace setting.
sexual harassment, and retaliation complaints State Fund follows the California Labor Code,
Retaliation Is Prohibited and to HR Employee Relations through the Ask Family Code, collective bargaining agreements,
Admin portal. You may also report equal and other applicable law affecting State
Not Tolerated employment opportunity concerns to the Equal Fund Workforce members who are victims of
State Fund prohibits retaliation and will not Employment Opportunity (EEO) Program, the domestic violence. State Fund also takes part in
tolerate persons who retaliate against anyone Internal Investigations Unit, or to a supervisor or Workplace Violence Prevention programs.
raising a discrimination, harassment, or sexual manager.
harassment issue.
You may report ethics or business concerns and
Retaliation for requesting a reasonable retaliation for reporting improper activities to
accommodation for disability or medical the Ethics and Privacy Hotline.
condition, or for religion, is also prohibited.
State Fund prohibits retaliating against or
harassing a Workforce member or employment
applicant who reports ethics or business
conduct concerns.
Page 14 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I MAINTAIN A SAFE AND HEALTHY ENVIRONMENT
Imminent Danger Threats in
IMPORTANT NUMBERS
the Workplace
Imminent Danger 911
Imminent danger means that you must believe
that death or serious physical harm could occur Employee Assistance Program (800) 339-2099
at the time of a threat.
Ethics and Privacy Hotline (888) 254-3401
If you believe there is an imminent danger to
you or other people, call 911, or contact local law
enforcement. Employee Assistance Program
After notifying law enforcement, report the At times, a personal issue or problem may
threat immediately to local management and interfere with your work-life balance. The State
to State Fund’s Threat Evaluation Team. Fund Employee Assistance Program (EAP)
gives you a confidential and free service to
Substance Abuse-Free Workplace help you or your family members. They provide
professional review and referrals to services
Substance abuse seriously threatens the
needed and help solve problems. EAP also
safety, health, and productivity of our business,
supports State Fund managers by providing
Workforce members, and customers. State
them with an expert resource.
Fund has a zero tolerance policy for drug and
alcohol impairment while employees are at the The Employee Assistance Program toll-free
worksite. telephone number is (800) 339-2099.
The State of California’s policy in California Code
of Regulations Title 2, Rule 599.960 states that
workplaces should be free from the effects
of substance abuse. This avoids dangers that
come from substance abuse in the workplace.
Dangers can include death and injury to you,
co-workers, or the public from accidents, poor
judgment, and carelessness.
Page 15 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I REPRESENT STATE FUND
Functions Involving Alcohol
There may be events you attend as a State Fund
Workforce member where alcoholic beverages
are available. In these instances, you are
responsible for your conduct, must make your
own decisions about alcohol consumption, and
follow all appropriate laws.
Consumption of alcohol in excess or to the level
of intoxication defined by California law is never
acceptable or condoned and is prohibited at
these events.
Financial Disclosures and the
Statement of Economic Interests –
Form 700 (SEI)
The California Political Reform Act and State
Fund’s Conflict of Interest Code require certain
members of State Fund’s Workforce to file yearly
financial disclosures. Statements of Economic
Interests, Schedules, and ethics course
certificates can be disclosed to the public.
I understand that how I conduct myself, both at the office and outside of work, reflects on State Fund as an
organization. It’s my responsibility to understand how my role ultimately affects our customers. For more information about annual
As a representative of this organization, it is important to make good choices that uphold our core values. disclosure requirements, contact the Fair
Remember to: Political Practices Commission (FPPC)
• Act professionally while traveling on State Fund business, during or after office hours. Information line at (866) 275-3772; visit
• Do not place yourself in situations that might result in diminished decision-making capacity. the FPPC website; or visit the California
• Exercise good judgement. Department of Justice, Office of the Attorney
• Behave respectfully toward vendors, injured workers, policyholders, and others with whom we do General website.
business.
• Avoid behaviors that pose a conflict of interest, or raise ethical or discriminatory concerns.
Page 16 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I REPRESENT STATE FUND
Click or tap the questions Q below to see the answers A .
Q If I am a designated filer, how often Gifts
do I need to file the Statement of State Fund follows:
Q I am a State Fund claims adjuster. Economic Interests, Form 700?
My spouse just began working as an y The Fair Political Practices Commission
underwriter at another insurance (FPPC) regulations Article 10 of the
company. Do I need to disclose this in California Government Code
my Form 700, Statement of Economic y Labor Code Section 3219 (Claims
Interests? Adjusters, only)
y Our Incompatible Activities policy
related to gifts
Individual departments at State Fund may
adopt more restrictive rules for acceptance
of gifts based on their role. Check with your
supervisor or manager when you have
questions about gifts.
Real or apparent conflicts can reduce the trust
our customers and the public have in State FPPC regulations define gifts as: any payment
Fund. Conflicts can also increase our legal or other benefit provided to you that confers a
risks and hurt our reputation. You must follow personal benefit for which you do not provide
Federal and California laws that affect your payment or services of equal or greater value.
work-related activities. Gifts include a rebate or discount in the price of
anything of value unless the rebate or discount
You must avoid situations that create, or appear
is made in the regular course of business to
to create, a conflict between your personal
members of the public.
interests and State Fund interests. When a
potential conflict arises, you must disclose it The FPPC requires that you must report gifts
to management and to Employee Relations over $50 from one source. For 2020, you may
right away. not accept more than $500 in gifts during
one calendar year from one source. You may
take no more than $10 a month from lobbyists
or legislative employees. Contact Employee
Relations with your questions. You may also
report internally to the Employee Relations
Department through the AskAdmin Portal.
Page 17 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I REPRESENT STATE FUND
You can also find more information at the Fair Personal Interest Disqualification When to Disqualify Yourself from
Political Practices Commission’s website. Decision-Making or Contracting
At times, to avoid a conflict of interest or the
Claims adjusters must follow special rules appearance of it, you must remove yourself State Fund Workforce members must disqualify
contained in Labor Code Section 3219. The Labor from making a decision or a contract process themselves from making decisions or contracts
Code prohibits you from taking a benefit that based on personal interest. when taking part in that process would violate
may look like a reward for referring or settling a the law, our Corporate Policies, or Code of
You must disqualify yourself from making, Conduct.
claim. Therefore, you may not take any gift from
taking part in, or trying to use your position to
doctors, applicant attorneys, or other vendors of Potentially disqualifying situations include:
influence a State Fund decision when you know
services for injured workers.
or should know you have a personal interest y Decisions in which you know or should know
in the outcome that differs from State Fund’s you have a personal financial interest or
Click or tap the question Q below to see the answer A .
interest.
y Decisions related to a State Fund contract in
State Fund strives to be fair, efficient, and which you have any type of personal direct or
Q Can I accept a gift basket from one of neutral when making contracts. You must never indirect financial interest or
State Fund’s computer services vendors give friends or family members an unfair or
I work with as a token of thanks for y Decisions related to a State Fund contract
seemingly unfair advantage in the contracting where you or an immediate family member
using their services? process. This means you should: also has an outside business relationship with
y Remove yourself from considering or a party to that contract which:
evaluating a business proposal made to State • Gives you better terms than members of
Fund by friends or family members. the public get.
y Never try to divert State Fund business • Is worth $1,000 or more and
opportunities to friends or family. • Your decision is made within the 12
y Never provide friends or family members months prior to State Fund’s decision or
insider information that the public does not
y Decisions made for State Fund where the
have to assist them in obtaining work from
decision relates to or affects a person or entity
State Fund.
with whom you:
y Avoid even the appearance of impropriety or
• Are negotiating for a job or
favoritism in contracting matters.
• Will be employed with in the future.
y Seek guidance of management or Employee
Relations if you have any questions about
business-related conduct.
Page 18 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I REPRESENT STATE FUND
California law defines the above situations. If State Fund has many laws to follow. For
a conflict exists between our Code of Conduct example, the information in our financial
and California law, California law controls. records, statements, and reports must
accurately reflect our financial condition, be
Reporting Failures to Disqualify
prepared in accord with laws and statutory
If you believe a Workforce member failed to accounting practices, and be filed timely. State
disqualify himself or herself when needed, Fund Officers must attest that our financial
you can report anonymously to the Ethics and reports are accurate and complete when
Privacy Hotline at (888) 254-4301 or online. issuing them.
You also can report confidentially and State Fund also complies with collective
anonymously to the California State Auditor. bargaining agreements and laws. State
You may also report internally to the Employee Fund cooperates with CalHR and union
Relations Department through the AskAdmin representatives to negotiate labor contracts
Portal. for State Fund employees.
Upholding the Law
When you know and follow laws and rules that
apply to your job at State Fund, you support our
commitment to integrity. Laws and rules affect
all State Fund business activities.
If you feel unsure about your legal duties, seek
advice from an “Appendix - Resources” on page
25. When you raise a concern, State Fund will
address it. You have a duty to speak up if you
notice possible legal violations and to cooperate
during investigations.
Page 19 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I USE RESOURCES RESPONSIBLY
Using State Fund Resources Click or tap the question Q below to see the answer A .
State Fund resources, including time, material,
equipment, and information, are for State Q Can I sell items such as cookies for a
Fund business use. You are trusted to behave charitable organization, products from
responsibly and use good judgment to conserve my personal business, or other items
company resources. Managers are responsible from my work area?
for their department’s resources and should
resolve issues about their proper use. If you have
questions about the proper use of State Fund
resources, go to management or Employee
Relations.
I exercise good judgement when using State Fund
resources such as supplies, computers, telephones,
internet access, and printers, and am committed to
guarding against waste and abuse.
Page 20 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I USE RESOURCES RESPONSIBLY
Using State Fund Click or tap the questions Q below to see the answers A .
You are entrusted to protect personal
Information Systems information we own, maintain, or send to
others in our daily work. Protecting information
State Fund’s Annual Proprietary System Notice Q I would like to respond to a lunch also means collecting or sending out only the
and Acknowledgement provides you guidance invitation from a friend at a different personal information needed for doing business.
on how to use State Fund electronic information company. Can I use the State Fund Our obligation extends to personal information
systems. Each year, you must acknowledge email system in this instance? we send to vendors and other third parties who
this notice. help us conduct business.
Our information systems include computer What is Personal Information?
equipment, internet, email, computer software,
Personal information in California is any
data, databases, electronic files, telephones,
information that identifies, relates to, describes,
voice mail, fax machines, wireless devices, and
or is capable of being associated with a
any other similar information technologies
particular person.
that State Fund currently uses or may use in Q I need to send my tax information to
the future. Apart from minimal and incidental my accountant on short notice. Can Personal information means a person’s
use permitted by law, contract, or specific I use the State Fund email system in first name or first initial and last name in
management exception, you must use State this instance? combination with any one or more of the
Fund systems exclusively to conduct State following:
Fund business.
y Social security number
State Fund may monitor its systems. You should y Address
not expect privacy regarding use, including
y Telephone number
personal use of State Fund Information Systems.
y Passport number, driver’s license number, or
You also have a duty to protect personal and state identification card number
confidential information about our Workforce, Protecting and Respecting
y Financial account numbers or any other
policyholders, claimants, and third parties. You Information financial information
must not access or use confidential information The California Constitution says every person
available to you due to your work at State Fund y Medical information
has an inalienable right to privacy. Because we
for personal gain. y Health insurance information
process and use private information in our work
every day, you have the daily responsibility to y Unique human physical characteristics
think about privacy and information security. y Insurance policy or claim number
y Education, employment, or employment
history
Page 21 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I USE RESOURCES RESPONSIBLY
Personal information does not include: Before you release any personal information, Respecting the Works of State Fund
you must: and Others
y Publicly available information lawfully made
available to the general public from federal, y Verify who the person is and State Fund protects and keeps private its trade
state, or local government records. y Confirm the person is authorized to get that secrets and proprietary information up to the
Only access, give out, or discuss personal information and maximum extent allowed by law. State Fund
information if you have an authorized business y Follow State Fund’s procedures for releasing does not infringe on the copyright interests,
reason to do so. Preventing unauthorized information. trademarks, or patented works (processes,
release of personal information helps protect machinery, or designs) of third parties.
You are accountable to restrict release of
State Fund and our stakeholders.
personal information to authorized individuals Copyright is:
under California and Federal laws and State y An exclusive right of ownership to an original
Click or tap the question Q below to see the answer
Question: A . Fund’s Policies. creative work by its author, including the
To report a suspected privacy incident, right to display, perform, distribute, and make
A former State Fund co-worker called contact the Privacy Office directly by calling copies of the work.
Q
and asked me to look up his friend’s (888) 724- 3237 or emailing to PrivacyOffice@ y The right of the owner to protect their work
claim and provide him status on it. scif.com. You may also raise your concerns from unauthorized or unlicensed use.
The former co-worker now works for anonymously by calling the Privacy Hotline
y Protected by the U.S. Constitution and U.S.
another insurance company and is toll-free anytime at (888) 254-4301 or online.
Copyright Law.
not part of the friend’s claim. Should We will provide you with a “safe landing spot”
I provide the information? if you wish to report incidents or raise questions Works are automatically copyrighted whether
or concerns. or not the author registers the copyright or
whether the work bears the word “copyright” or
The Privacy Office provides you with resources the “©” symbol.
for privacy protection.
Before you use or send other’s material or
images that may be copyrighted, trademarked,
or patented, contact the Governance
department at Copyright@scif.com to make
sure you have the permission to do so.
The Copyright Office provides resources about
copyrights and how to obtain permission to use
the creative works of others.
Page 22 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
HOW I DO MY PART TO KEEP CALIFORNIA WORKING
Sharing Your Ideas Since public records requests have important
time limits, make sure to send requests you
When you raise ideas to make State Fund
may get to our PRO right away.
a better place or bring up questions to help
prevent making mistakes or wrong choices, You as an employee can also request
it benefits State Fund. public records from State Fund under CPRA.
State Fund cannot retaliate if you exercise
If you are a manager:
these rights.
y Set the tone and create an open environment
so others feel at ease raising their concerns. Transparency — Bagley-Keene
y Consider if it is appropriate to move employee Open Meeting Act
ideas forward and do so whenever possible. State Fund is subject to the Bagley-Keene
Many departments also have ways to share Open Meeting Act. This act makes certain
ideas, such as physical or electronic suggestion meetings open to the public, such as meetings
boxes. of the Board and the Board Committees of
Audit, Governance, and Investment and Risk.
You can also share ideas or raise concerns
Having open meetings helps keep government
anonymously, without fear of retaliation,
accountable and transparent and protects
through available “HOTLINES” on page 25
citizens’ rights to take part in state government.
or online.
You have the same rights as the public under
Transparency — California the Act. State Fund cannot retaliate if you
Public Records Act exercise these rights.
State Fund is committed to complying fully with
Workers’ Compensation Fraud
the California Public Records Act (CPRA) and
other laws governing the disclosure of records. You can report suspected workers’
We must follow the law by responding when compensation fraud by policyholders, injured
anyone submits a public records request to us. workers, vendors, or State Fund Workforce
I invest the time and resources needed to seek out
State Fund authorizes only the Public Records members by calling (888) 786-7372 or by filing
solutions to help California businesses and injured
Office (PRO) to evaluate, respond to, and a TIP report through State Fund’s Special
workers. I am committed to continually doing my Investigation Unit’s internal website.
manage State Fund’s public record requests.
best for our customers.
Page 23 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
ACKNOWLEDGING AND SUPPORTING THE CODE AND RELATED POLICIES
State Fund requires you to certify electronically
that you read, understand, and will follow State
Fund’s Code of Conduct and its supporting
Policies.
Failing to support the Code of Conduct
including its related Policies and completing
the acknowledgement, may result in referral
for disciplinary action up to and including
termination.
You are responsible for reporting and
cooperating with investigations of any Code
or Policy violations. State Fund promptly
investigates all reports of violations.
See the Governance site for the
Corporate Policy Library.
Page 24 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
APPENDIX - RESOURCES
1 HOTLINES
State Fund Ethics and Privacy Hotline (888) 254-3401
https://ethicsandprivacyhotline.ethix360.com/
This website operates more efficiently in the Chrome browser.
Workers’ Compensation Fraud (888) 786-7372
California State Auditor Whistleblower Hotline (800) 952-5665
2 KEY STATE FUND POLICIES SUPPORTING THE CODE
CORPORATE POLICY POLICY TYPE POLICY NUMBER
Privacy & Confidentiality Ethics Compliance & Fraud EC&F 2.0
Complaint Reporting & Anti-Retaliation Ethics Compliance & Fraud EC&F 2.1
Incompatible Activities Ethics Compliance & Fraud EC&F 2.2
Business Ethics Ethics Compliance & Fraud EC&F 2.3
Statement of Economic Interests & Financial Disclosure Ethics Compliance & Fraud EC&F 2.4
Use of State Fund Facilities for Non-Business Use Ethics Compliance & Fraud EC&F 2.7
Discrimination, Harassment, Sexual Harassment, and Human Resources HR 4.1
Retaliation Prevention
Page 25 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
APPENDIX - RESOURCES
3 STATE FUND DEPARTMENTS
DEPARTMENT CONTACT FOR PHONE/EMAIL
Employee Assistance Program Confidential access, assessment, & referral to professional assistance for (800) 339-2099
problem resolution
Equal Employment Opportunity Diversity, Discrimination and Reasonable Accommodation Issues eeo@scif.com
Governance State Fund Corporate Policies & Procedures; Copyright; State Fund Charter; (888) 724-3237
Governance Guide corporatepolicies@ scif.com,
copyright@scif.com
Internal Audit Proper use of State Fund resources (707) 624-4583
Enterprise Security Proper use of information systems EnterpriseSecurity@scif.com
Privacy Office Privacy & Confidentiality questions (888) 724-3237 (office)
(866) 294-1742 (Privacy incident hotline)
PrivacyOffice@scif.com
Public Records Office Records requests made under the CA Public Records Act (888) 724-3237
publicrecords@scif. com
Real Estate Management Services Threat Reporting (925) 523-5219
Imminent danger: 911
threatmanagement@scif.com
Special Investigation Unit Workers’ Compensation Fraud (888) 786-7372
(323) 266-5138
Page 26 | ©2021 State Compensation Insurance FundCode of Conduct for All State Compensation Insurance Fund Workforce Members
APPENDIX - RESOURCES
4 STATE AGENCIES
DEPARTMENT CONTACT FOR PHONE/EMAIL WEBSITE
Attorney General’s Office/California Statements of Economic Interests, Ethics PO Box 944255 www.oag.ca.gov
Department of Justice Sacramento, CA 94244
(800) 952-5225
California State Auditor Whistleblower complaints 555 Capitol Mall, Suite 300 www.bsa.ca.gov
Bureau of State Audits Sacramento, CA 95814
(916) 445-0255
Department of Insurance Insurance complaints Consumer Communications Bureau www.insurance.ca.gov
300 South Spring St., South Tower
Los Angeles, CA 90013
(800) 927-4357
Fair Political Practices Commission Statements of Economic Interests 428 J Street, Suite 620 www.fppc.ca.gov
Sacramento, CA 95814
(866) 275-3772
State Personnel Board Whistleblower Retaliation complaints 801 Capitol Mall www.spb.ca.gov
Sacramento, CA 95814
(916) 653-0799
5 CALIFORNIA LAWS
LEGAL RESOURCE LINK
California Constitution and Laws Website Link
Incompatible Activities – all employees California Government Code (Section 19990)
Incompatible Adjuster Activities Labor Code (Section 3219)
California Regulations Website Link
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