Family seating couch.

Policies

Truth in Advertising

This policy guides staff on all commercial advertising on Crossroads Homecare’s websites, social

media channels and printed collateral.

POLICY

The term advertising is defined as the activity of attracting public attention to a product or

business through paid announcements. Employees are directed to follow this advertising policy

for all advertising that promotes Crossroads Homecare and/or it’s services.

GUIDLINES

The following guidelines apply to all advertising.

The advertising content shall be clearly identifiable as an advertisement,

Advertising content cannot mislead the user.

Advertising and advertisements must be truthful and non-deceptive.

Advertisements must have evidence-based proof to back up any and all claims made.

Advertisements cannot be unfair.

Comparisons – Claims do not make any false, misleading or un-substantiated statements about

competitors and routinely does not use this type of advertising.

Price Claims – All fees quoted are legitimate and not misleading.

Taste and Decency – The organization ensures that all its communications are free of statements,

illustration or implications, which are offensive to good taste or public decency.

Testimonials – Testimonials used are those of real clients or their family members and reflect

real and honest opinions about their experience with the services and supported by written

documentation.

Bait Advertising – The organization does not use this type of advertising for any service it offers.

Truth – All facts are true and revealed so as not to mislead anyone, this includes services allowed

by credentials/license.

DEFINITIONS

An advertisement can be considered unfair if:

It is known to, or likely to, cause significant injury to consumers that cannot be reasonably

avoided, and

If that risk is not outweighed by any benefits to consumers.

When is an Advertisement Considered “Deceptive?”

Much like the term “unfair,” “deceptive” carries its own definition.


The ad is likely to mislead consumers that are acting under normal and reasonable

circumstances, and

ADDITIONAL RESTRICTIONS

All employees must wear, during patient encounters, a name tag that clearly identifies the type of

license they hold.

Fraud

PURPOSE

The corporate fraud policy is established to facilitate the development of controls that

will aid in the detection and prevention of fraud against Crossroads Homecare. It is the

intent of Crossroads Homecare to promote consistent organizational behavior by

providing guidelines and assigning responsibility for the development of controls and

conduct of investigations.

POLICY

This policy applies to any irregularity, or suspected irregularity, involving employees as

well as shareholders, consultants, vendors, contractors, outside agencies doing business

with employees of such agencies, and/or any other parties with a business relationship

with Crossroads Homecare (also called the Company). Any investigative activity

required will be conducted without regard to the suspected wrongdoer’s length of service,

position/title, or relationship to the Company.

DEFINITIONS

Management is responsible for the detection and prevention of fraud, misappropriations,

and other irregularities. Fraud is defined as the intentional, false representation or

concealment of a material fact for the purpose of inducing another to act upon it to his or

her injury. Each member of the management team will be familiar with the types of

improprieties that might occur within his or her area of responsibility and be alert for any

indication of irregularity. Any irregularity that is detected or suspected must be reported

immediately to the Director of Client Care, who coordinates all investigations with the

Legal Department and other affected areas, both internal and external.

TERMINATION

If an investigation results in a recommendation to terminate an individual, the

recommendation will be reviewed for approval by the Director of Client Care and, if

necessary, by outside counsel, before any such action is taken.