CORPORATE INDEPENDENCE POLICY

Donn & Company (DonnCo) operates under a core principle of transparent objectivity, meaning DonnCo is committed to providing unbiased opinions, research, and analysis that is singularly aligned with the interests of our clients. To ensure the practice and continuance of this principle, DonnCo enforces the following corporate financial guidelines:

MANAGED CARE COMPANY (MCC) CLIENT RESTRICTION: DonnCo does not enter into client relationships with or accept engagements from companies that directly provide workers’ compensation managed care cost containment services, including (medical bill review, PPO, utilization review and case management services) or group health PBM services.

FINANCIAL INDEPENDENCE: In the course of client engagements and general research processes, DonnCo representatives often interact with MCC’s and their representatives. As a fundamental guideline, DonnCo representatives do not accept any direct or indirect compensation from DonnCo’s. Specifically, DonnCo employees do not accept any of the following:

any meals or entertainment compensation
any direct financial considerations to employees, their friends or family
any securities or financial instruments of any type
any travel expense reimbursements
any gifts exceeding $25 in value (gifts under $25 in value are donated to local charities)

CONFLICT OF INTEREST: All DonnCo employees are restricted from holding any securities or financial interests in companies or organizations that directly provide workers’ compensation managed care cost containment services or group health PBM services, including the equities, bonds, warrants, etc. of any public or private entity providing one or more of the cost containment services researched by DonnCo, unless held through shares of a mutual fund or other similar composite security.