's Physician Recruitment Code of Ethics

strictly adheres to the ethical guidelines laid forth by the National Association of Physician Recruiters.  As a member firm, is committed to conducting physician recruitment under these ethical guidelines.  The following are those guidelines:

I. PREAMBLE

The Code of Ethics is the principles and standards we of  the National Association of Physician Recruiters have agreed  to as a condition of membership. Our commitments, actions  and professional conduct are reflected in the following Code  and represent the manner by which each of our organizations  fulfills its obligations to other members, the general  public, clients and candidates. The establishment of these  rules of conduct is to distinguish our members and to reflect the pride of our commitment to fulfilling the needs  of those for whom we provide service as well as our  colleagues.

II. DEFINITIONS

A. Affiliate: Any company whose governance, control or  voting influence represents common ownership of at least  five percent of the related company.

B. Board of Directors: The Board of Directors of the  National Association of Physician Recruiters.

C. Candidate: An individual who contacts an NAPR member,  or who is contacted by an NAPR member for the purpose of  securing a practice or employment opportunity.

D. Chairperson, Ethics Committee: Appointed by the NAPR  President, chairs all meetings of the Ethics Committee.

E. Client: Any organization which contracts with an NAPR  member to recruit or which utilizes paid services provided  by an NAPR member.

F. Code: The National Association of Physician  Recruiters' Code of Ethics.

G. Complainant: A person or organization who files a  complaint alleging violation of the Code.

H. Complaint: A written charge by a complainant alleging  violation of the Code.

I. Curriculum Vitae: A summary of one's personal history  and professional qualifications.

J. Ethics Committee Investigator: That member of the  Ethics Committee assigned by the Chairperson of Ethics to  gather and evaluate all relevant information about a  specific complaint filed with the Committee.

K. Financial Relationship: A relationship with a client  in which any or all of the agreed upon fee is paid prior to  the placement of a candidate or in which the client has  contractually (oral or written) agreed to reimburse the firm  for any or all costs associated with the search.

L. Member: An organization, recruiting firm, or  individual which is a member of NAPR.

M. NAPR: The National Association of Physician  Recruiters.

N. NAPR Subsidiary: Any company in which NAPR owns or  controls all or a majority of the corporate shares.

O. Potential Client: Any organization which contemplates  contracting with a NAPR member to recruit or which  contemplates contracting for paid services provided by a  NAPR member.

P. President: Chief elected officer of NAPR.

Q. Procuring Cause: That entity which sets in motion a  continuous series of events culminating in a placement.

R. Recruiter: An individual whose professional activities  are in full or part involved in the placement of physicians  or healthcare providers in their own or other organizations.

S. Referral: A Candidate requested by an organization or  a Candidate presented by an NAPR member to an organization  seeking to recruit.

T. Respondent: An organization, firm, or individual  member which has allegedly violated the Code.

U. Right of Representation: A document which ascribes the  right of the recruiting organization to represent the  candidate on an exclusive basis to one specifically defined  opportunity.

V. Standards: NAPR Standards of Practice and Procedures.

W. Subsidiary: Another company controlled by a member  company which owns all or a majority of its shares.

X. Professional Conduct: A desirable pattern of commonly  accepted behavior utilized in the deportment of, actions by  and communications with other individuals or organizations  utilized in the course of conducting one's business or  personal relationships.

Y. Ruse: A trick or scheme for achieving some purpose.

III. ETHICAL RULES

A. Relations with Clients and Potential Clients

1. A member shall reasonably fulfill all agreements made  with anyone with whom they conduct business or wish to  conduct business. 2. A member shall preserve all confidences  of a client or a potential client regarding information  concerning business practices of the client, unless  expressly directed by the client to reveal such confidences.  3. A member shall not make disparaging remarks about  competitors or competing opportunities or knowingly make a  false statement of fact to a client or another member or  non-member. A member shall state to the client as accurately  as possible a candidate's employment history, qualifications  and salary requirements. 4. A member shall not make an  unsolicited referral for the purpose of charging a fee. A  member shall not present or refer, either in person, or by  curriculum vitae or by name, a candidate to a client, a  potential client or another firm except at the request of  the client or firm and only if the candidate's name and  address are identified, and only with the candidate's  knowledge and permission; however, a member may refer a  candidate to multiple opportunities if the candidate has  given the member express permission to do so. 5. A member  shall thoroughly examine a candidate's education, employment  history and qualifications before referring such candidate  to a client, a potential client or another firm unless the  client, potential client, candidate, or firm has requested  otherwise, and shall refer a candidate to them only if the  candidate generally possesses the qualifications designated  by the above mentioned and the candidate expresses an interest in the opportunity. 6. A member shall negotiate a  fee with a client or a potential client or another  recruiting firm. The fee obligation shall be fully disclosed  preferably in a written agreement signed by the client  and/or firm. 7. A member shall not initiate the performance  of services for a client if: a. the performance of services  will result in violation of this Code or of any applicable  law; b. the member learns that the client has used the  member's services in the past to commit actions violative of  this Code or of any applicable law; c. the condition will prevent the member from performing full and fair services  for a client. 8. A member shall comply with all federal,  state and local laws. 9. A member shall conduct its business  with any client or potential client utilizing reasonable  standards of professional conduct.

B. Relations with Candidates

1. A member shall not knowingly make a false statement to  a candidate and shall state to a candidate as accurately as  possible the pertinent information concerning prospective opportunities. 2. A member shall not present a candidate's  name or curriculum vitae to a client, a potential client or  another firm except with the consent of the candidate and  after full disclosure of the client or other firm's name and  location. 3. Firms will not fax, e-mail or otherwise distribute curriculum vitae of candidates without a prior  contractual agreement with a client or potential client.  Regardless of the contractual relationship, no curriculum  vitae shall be distributed without first clearing the  candidate's name; that is, that the client acknowledges that  the candidate is not previously known to the client or is  not active in the recruitment process at the time the  recruiting firm introduces the candidate to the client. 4. A  member, who has a financial relationship with a client shall  not recruit or attempt to recruit a candidate from them  while this financial relationship exists and for a period of  one (1) year following the last placement with the client  (excluding interns, residents, or fellows in training)  unless the candidate has previously notified the client of  his or her intent to seek another position. 5. A member  shall not refer a candidate to a client, potential client or  another firm whose business practices are known to be violative of the Code or of any applicable law. 6. A member  shall not ruse candidates, clients or other persons and  shall not impersonate candidates or clients. 7. A member  shall preserve all confidences of the candidate. 8. A member  shall not make disparaging remarks about competing practices  or knowingly make a false statement to a candidate. 9. A  member shall conduct its business with any candidate or  potential candidate utilizing reasonable standards of  professional conduct. 

C. Cooperation in Investigations and Enforcement

1. An Ethics' case will not be considered by the  Committee Chair or the Committee unless the complainant has  attempted to resolve the conflict directly with the other  entity, unless an attempt to do so will potentially lead to  further disagreement or the violation is so blatant as to  warrant immediate action. 2. A member under investigation by  the Ethics Committee shall cooperate fully, personally,  directly and in a timely manner with the Ethics Committee  and its investigator or Board of Directors concerning the  alleged violation of the Code (and will honor requests for documentation, testimony, or explanation of the facts and  circumstances). 3. A member that reasonably believes that  another member has committed a violation of the Code shall  inform the NAPR Headquarters Office and/or the Chair of the  Ethics Committee who will make an initial determination as  to the validity of the potential violation after  consultation with the President of the NAPR. 4. A member  accused of a Code violation must respond to all procedural  requirements of the investigation process and communicate  directly with the investigator.

D. Advertising and Other Communications

1. A member shall not in the course of its advertising,  marketing, or other communications make a false or  misleading statement about its organization, firm or  services, or about another organization or its services. A  statement will be considered false if: a. it contains a  material misrepresentation that violates the spirit of the  Code of Ethics or omits a fact which would make the  statement as a whole or in part misleading; b. it is likely  to create an unjustified expectation about the results the  member can achieve, or states or implies that the promised  results which, if achieved, will violate the Code or any  applicable law; c. it makes a comparison of the member with  another member that cannot be factually substantiated. 2. No  member or its representatives shall knowingly or unknowingly  misrepresent or malign the position of the National  Association of Physician Recruiters or its members. 3. A  member that lists potential employment opportunities in all  types of media or directly to a candidate shall ensure that  such opportunities in fact exist at the time of making such  listing. 4. A NAPR member who owns, is affiliated with, or  is related to a person or entity which markets services or  products other than physician recruitment (job bank, web  hosting, software, networks and/or alliances, etc.), must  notify NAPR headquarters and also identify themselves by the  name and company known to NAPR members in any communication (verbal, letter, fax, e-mail) which advertises such services  to other members. a. Additionally no candidate registered  with the World Job Bank, Cooperative Mailing Program or any  future member service may be contacted for any purpose other  than to present practice opportunities (jobs). 5. The World  Job Bank, Cooperative Mailing Program or any future member  service involving candidates are provided to participants  for the sole purpose of advertising each organization's  practice opportunities to registered candidates. These  member services must be utilized strictly for their stated  purpose. Transferring registered candidates to any other  entity in whole, part or individually without first  contacting the candidate and receiving their consent, constitutes a breach of the Ethics Code.

E. Relations With Other Organizations Or Individuals

1. All members must compete in a fair and honorable  manner. a. Never discredit the reputation of any person or  organization; b. Honor agreements made between members and  refrain from defaming, maligning or falsely accusing any  person or other organization. c. Refrain from intentionally  misrepresenting any person or opportunity to a prospective  candidate or client or another firm; d. Act professionally  and in a businesslike manner; e. Not engage in a deceptive  or misleading manner; f. Honor both oral and written  agreements; g. Not engage in any activity which brings  dishonor to the industry; h. Adhere to all EEOC and state or  local affirmative action rules and regulations, as well as  all local, state and Federal laws.

F. Relationships Between In-House Recruiters And  Recruiting Firms

1. In-house recruiters shall maintain an accurate  tracking system to record the submission of candidates by  recruiting firms and shall respond to the firm as to the  acceptability of the referral within five (5) business days.  2. The submission of a candidate to a client organization  utilizing a physician database shall be deemed unacceptable  if the client has been in contact with the referred  candidate within the past thirty (30) days and has scheduled  or is in the process of scheduling an interview. 3. In-house  recruiters shall not accept unsolicited Curriculum Vitae  from a member and shall notify the recruiting firm  immediately of the invalid referral.

4. In-house recruiters may not refer a candidate  presented to them by a member to any other entity without  written permission from the referring member, except for  referrals made to practices whose physicians are employed by  or who are on the active staff of the organization and for  which they will pay the contracted fee. 5. In-house  recruiters should not accept a referral from any member that  is believed to be in violation of the Code of Ethics. 6.  In-house recruiters will only accept a referral from an  entity which has set in motion a continuous series of events which through its ongoing efforts with both the candidate  and client could result in a hire.


IV. ETHICS COMMITTEE

A. There shall exist an Ethics Committee which will  consider any complaint, first reviewed by the President of  the NAPR and the Ethics Committee Chairperson.

B. The Ethics Committee shall consist of the Chairperson  and a minimum of five (5) members. The Chairperson is  appointed by the President of NAPR for a three-year term.  Five (5) of the members shall be individuals employed by  active member organizations of NAPR and appointed by the  Ethics Committee Chairperson with Board of Directors  approval for a three-year term. A Vice-Chairperson, who will  succeed the Chairperson, shall be appointed by the Ethics'  Chairperson and approved by the Board of Directors. The  succession will occur only if the Ethics' Chairperson is not  reappointed or resigns. The Chairperson and committee  members may succeed themselves. C. The Ethics Committee  shall be responsible for reviewing and acting upon reported violations of the NAPR Code of Ethics or may, on its own  initiative, file a complaint.

V. GRIEVANCE PROCEDURES

A. Complaints

1. The Ethics Committee shall review and adjudicate only  those issues or events which are deemed to be in violation  of the Code of Ethics. Not included in this jurisdiction are  disputes between entities involving fees and candidate  referrals and disputes between employers and employees  (unless those referrals, fees and disputes involve a  violative action). 2. A complaint may be filed with NAPR by  anyone who has a complaint against an NAPR member. The  complaint must be in writing and shall describe the incident  and shall be accompanied by any supporting material to allow  action on the complaint. All complaints must be received  within twelve (12) months of alleged violation. Complaints  arising beyond the twelve (12) month period will be reviewed  by the Ethics Committee to determine if extenuating  circumstances prevented timely action on the complaint. 3. A  complaint must be filed in writing and sent directly to the  NAPR Headquarters Office. If the complaint is filed with the  Ethics Committee or a member thereof, the Ethics Committee  shall transmit the complaint to the NAPR Headquarters  Office. 4. In the event that a case is brought before the  Ethics Committee which involves either a director or a  member of the Ethics Committee, that member will not  participate in the decision process. 5. The President and  the Ethics Committee Chairperson shall consider any and all  complaints concerning violation of the Code. If the NAPR  President and Ethics Committee Chairperson find a reasonable cause, they shall refer the complaint to the Ethics  Committee and the Chairperson shall assign the case to an  Ethics' Committee Investigator.

B. Ethics Committee Determination

1. If the complaint is referred to the Ethics Committee,  the Chairperson of the Ethics Committee shall notify the  respondent by certified return receipt mail that a complaint  against respondent has been forwarded to the Ethics  Committee and the Ethics Committee will investigate the complaint. The certified letter will be sent to the  respondent with a copy to the complainant within two (2)  weeks of the receipt of the complaint by the Ethics  Committee. The certified letter will: a. contain a copy of  the complaint; b. contain a copy of the NAPR Code of Ethics;  c. advise respondent of the right to respond to the  complaint; d. advise the respondent of the right to offer evidence in written form; e. outline what areas of the Code  are deemed in violation.

C. Investigation Process

1. Respondent must file a response to the complaint in  writing within thirty (30) days after the notice of  complaint is sent to respondent. If respondent fails to  answer the notification within the thirty (30) day period,  the Ethics Committee may proceed with the determination of  the complaint and state its final disposition. 2. The Ethics  Chair will assign an Ethics Committee Investigator who will  investigate the complaint and make a recommendation to the  Ethics Committee. The committee will vote on the  recommendation. 3. If, after the hearing, the committee  determines that a violation exists, a sanction may be  imposed by a majority of the committee. Voting may be either  in person or by telephone conference call. 4. The committee  may impose any one or more of the following sanctions:  Caution, Reprimand, Probation, Suspension or Expulsion. 5.  The respondent and complainant shall be notified of the  decision in writing by certified mail from the Ethics  Committee within thirty (30) days of the date of receiving  the response from the respondent.

D. Appeal to Board of Directors

1. Following a decision of the Ethics Committee, a  respondent will have the right to appeal the decision to the  Board of Directors. A respondent wishing to appeal will file  a written statement concerning the basis for the appeal with  NAPR. (No additional evidence will be permitted after the Ethics Committee ruling unless requested and approved by the  Board of Directors.) The Board of Directors shall, within  thirty (30) days of receipt of the written statement, review  that statement and either grant or deny the request for the  appeal. The decision of the Ethics Committee will stand  until the Board of Directors makes its determination.

2. All proceedings before the Board of Directors shall be  recorded.

3. In the event a case is brought to appeal before the  Board of Directors and involves a member of the Board, that  member will be excused from participating in all phases of  the case.

E. The Board of Directors within thirty (30) days  following the hearing of the appeal will report its final  decision to complainant and respondent by certified mail.  This will be done by the President of the NAPR.

F. Effective Date: Any sanction imposed shall be  effective on the date the time for appeals has expired  following the Ethics Committee's decision, or if a  respondent appeals to the Board of Directors, the date that  the Board has rendered its decision on the appeal.

G. Member In Good Standing: A member shall maintain its  status of "good standing" until one of the  following events has occurred: The member's dues are unpaid  as of February 15 for their current membership year defined  as January to December; a member has violated the Code of Ethics and has received a sanction of Probation, Suspension  or Expulsion.

Should a member fail to pay its current year's dues while  an Ethics Investigation is pending, its status shall be  "resigned pending the outcome of an alleged Ethics Code  Violation Investigation." Regardless of such  resignation, NAPR shall continue with and complete such  Ethics Investigation and shall issue appropriate sanctions.  If a sanction of Probation (six (6) months or more) is imposed after due process, and the member resigns or has  resigned from the NAPR its status shall be "resigned,  not a member in good standing."

VI. SANCTIONS AND DEFINITIONS

A. Caution: A written warning to the respondent  indicating a minor violation of the Code has occurred and  that similar or cumulative violations could result in a more  severe sanction.

B. Reprimand: A private communication precipitated by the  respondent for conduct in which the respondent repetitively  is violative of the Code or in which the severity of a  first-time violation warrants such action. Multiple  convictions for Code violations requires a minimum of one  month Probation with loss of access to all services, use of  the NAPR logo and loss of status as a member in good  standing. There will be no refund of dues previously paid.

C. Probation: A member's privileges will be revoked for a  period of up to 12 months during which time should  additional violative conduct occur, then the member shall be  suspended or expelled. During a period of probation, the  organization on probation may not state that it is a member  of NAPR in good standing in any written or oral  communications. It may not have use of the NAPR logo or  access to any services offered by the NAPR and its  subsidiary companies. Furthermore, it will not be allowed to  attend any of the NAPR meetings. There will be no refund of  dues previously paid.

D. Suspension: A period of up to 18 months during which  time a sanctioned member may not state that it is a member  of NAPR in good standing in any written or oral  communications. It may not have use of the NAPR logo nor  access to any services offered by the NAPR and its  subsidiary companies. Furthermore, it will not be allowed to  attend any of the NAPR meetings. At the conclusion of that  period, the organization's membership will be reviewed by  the Board of Directors at its next regularly schedule  meeting. There will be no refund of dues previously paid.

E. Expulsion: Expelled organizations may reapply for  membership after 3 years. Furthermore, it will not be  allowed to attend any of the NAPR meetings. There will be no  refund of dues previously paid.

F. Corrective Action(s): In addition to the appropriate  sanction(s) for Code violations, the respondent will be  notified by the Ethics Committee of supplemental corrective  action(s) which may be required. Non-compliance with these  corrective actions could result in more severe sanctions.

G. Publication: If the Board of Directors deems it useful  for educational purposes, the Board of Directors may publish  a summary of the outcome of the Ethics' case in which the  outcome resulted in a sanction of Probation of five (5)  months or less. Under this sanction, reasonable efforts will  be made to protect the confidentiality of individuals. In  doing so, the participants will have their names omitted.  Any sanction against a respondent which includes probation  of six (6) months or more, suspension (for any length of  time) or expulsion will be published in the next regularly  scheduled NAPR Newsletter to the membership. The  announcement will include the salient facts of the case  including the respondent corporate name(s) and respondent  individual names, but will exclude the name of the claimant.

H. Confidentiality: All information gathered in the  course of investigations by the President and Ethics'  Committee Chairperson, the Ethics Committee or the Board of  Directors, shall be confidential except as noted previously  and shall remain known only to those entities and their members or employees involved in the complaint.

I. When contacted, the NAPR will, give the membership  status of a member and state if asked, whether that member  has ever been in violation of the Code of Ethics. The NAPR  will disclose only those that have resulted in Probation,  Suspension or Expulsion. No other sanctions will be disclosed nor will the details of such actions be revealed  except as noted previously.

Revised May 2003