Policy and Procedures

Because Cardinal Health is a supplier to Government Agencies we are required to uphold Federal Acquisition Requirements (FARs) Clauses and insure that our Suppliers also uphold them as well.

Incorporation of FARs Provisions. Cardinal Health and Supplier will comply with all international, federal, state and local laws and regulations applicable to its operations, including but not limited to (i) all applicable customs and import/export laws, including rules of origin marking, (ii)all applicable provisions of the Federal Acquisition Regulation ("FAR") and the Defense FAR Supplement ("DFARS"), which is hereby incorporated by references if fully set forth herein, and which requires "flow down" of the following clauses: (a) 52.203-13 Contractor Code of Business Ethics and Conduct (APR 2010) (Implementing 41 U.S.C. 251 note)); (b) 52.219-8 Utilization of Small Business Concerns (MAY 2004) (Implementing 15 U.S. C. 637 (D)(2) & (3)); (c) 52.222-26 Equal Opportunity (MAR 2007) (implementing E.O. 11246 and 41 C.F.R. 60-1.4 and 60-2); (d) 52.222-35 Equal Opportunity for all covered veterans (SEP 2006) (implementing 38 U.S.C. 4212(a) and 41 C.F.R. 60-250 as well as 41 C.F.R. 60-300); (e) 52.222-36. Affirmative Action for Workers with Disabilities (JUN 1998) (implementing 29 U.S.C. 793 and 41 C.F.R. 60-741); (f) 52.222-37 Employment Reports on Special Disabled Veterans, Veterans of the Vietnam Era, and other Eligible Veterans (SEP 2006) (38 U.S.C. 4212); (g) 52.222-40 Notification of Employee Rights Under the national Labor Relations Act (DEC 2010) (Implementing E.O.13496); (h) 52.222-50 Combating Trafficking in Persons (FEB 2009) (22 U.S.C. 7104(g)); and (i) 52.225-13 Restrictions on Certain Foreign Purchases (DEC 2003).

Equal Employment Opportunity/Electronic Code of Federal Regulations/Non-Discrimination. Cardinal Health is an equal opportunity employer and federal contractor or subcontractor. Consequently, the Parties agree that, as applicable, they will abide by the requirements of 41 C.F.R. §§§ 60-1.4(a), 60-300.5(a) and 60-741.5(a) and that these laws are incorporated herein by reference. These regulations prohibit discrimination against qualified individuals based on their status as protected veterans or individuals with disabilities, and prohibit discrimination against all individuals based on their race, color, religion, sex, or national origin. These regulations require that covered prime contractors and subcontractors take affirmative action to employ and advance in employment individuals without regard to race, color, religion, sex, national origin, protected veteran status or disability. The parties also agree that, as applicable, they will abide by the requirements of Executive Order 13496 (29 CFR Part 471, Appendix A to Subpart A), relating to the notice of employee rights under federal labor laws.

In addition, Supplier shall comply with Executive Order 12989, subpart 22.18 (the E-Verify regulation), if applicable. Furthermore, it is the policy of Cardinal Health not to engage in any discrimination practices based on race, religion, sex, color, national origin, ancestry, age, physical or mental disability, sexual orientation, gender identity/expression, veteran status, pregnancy, marital status, creed, status with regard to public assistance or any other status protected by federal, state or local law (“Protected Class”). It is also the practice of Cardinal Health to do business with only those companies which also prohibit discrimination and to the same extent as enumerated under Cardinal Health’s policy. Supplier hereby represents that it is an equal opportunity employer and agrees not to discriminate against any member of the Protected Class in its employment practices. Supplier further agrees not to discriminate against qualified individuals with disabilities in any aspect of employment and shall make reasonable accommodations to disabled individuals who are otherwise qualified, so long as such accommodations do not cause an undue hardship.

Supplier Diversity. As a prime contractor to the federal government, Cardinal Health has certain obligations and requirements that it must satisfy in complying with all FARs, specifically Sections 19.704 and 51.219-8/9.  Additionally, as a prime contractor to the federal government and in accordance with our corporate values, Cardinal Health is committed to being inclusive regarding the utilization of small, small disadvantaged, small women-owned, veteran, service disabled veteran, Alaska Native Corporations, Indian tribes, and HUBZone based business concerns (“Small Business Groups”).  If your company is a designated large business entity, based on the Small Business Administration guidelines; www.sba.gov/size/ and is awarded a Cardinal Health contract with a projected value of $700,000 or more, $1,500,000 or more for construction of a public facility as stated in FAR 19.704(9), your organization shall be  expected to support Cardinal Health’s accountability by affording  further subcontracting opportunities to the Small Business Groups, when practicable.  Additionally, your organization agrees to track all subcontracting expenditures with the Small Business Groups, relative to our contract, and submit quarterly reports on the template provided, to Cardinal Health’s mailbox,supplierdiversity@cardinalhealth.com .  Finally, the organization will designate a primary point of contact within its organization, that carries the responsibility for meeting the flow-down requirements and identify that designee to Cardinal Health.

Qualification to Participate. In accordance with the provisions of 48 C.F.R. 52.209-6, Supplier represents, warrants and certifies that neither it nor its principals was or is debarred, suspended, proposed for debarment or otherwise determined to be ineligible to participate in federal health care programs (as that term is defined in 42 U.S.C. 1320a-7b(f)) or convicted of a criminal offense related to the provision of health care items or services, but has not yet been debarred, suspended, proposed for debarment or otherwise determined to be ineligible to participate in federal health care programs. In the event that Supplier, or any of its principals, is debarred, suspended, proposed for debarment or otherwise determined to be ineligible to participate in federal health care programs or convicted of a criminal offense related to the provision of health care items or services, Supplier will notify Cardinal Health immediately.

Child Labor. Supplier represents and warrants that it complies with and shall continue to comply with all federal, state, local and other applicable laws, regulations, conventions or treaties prohibiting any form of child labor or other exploitation of children in the manufacturing and delivery of Supplier's products or services.

No texting while driving - Supplier shall comply with 48 CFR 652.223-18, if applicable. In such case, Supplier shall adopt and enforce policies that ban text messaging while driving Supplier owned or rented vehicles or government-owned vehicles, and in privately-owned vehicles when providing Services for or on behalf of Cardinal Health, any customer of Cardinal Health, or the government. Supplier also shall conduct (a) initiatives to enforce the texting while driving policy in a manner commensurate with the size of the business, such as establishing rules and programs or re-evaluation of existing programs to prohibit text messaging while driving, and (b) education, awareness, and other outreach to employees about the safety risks associated with texting while driving. Supplier also shall include the requirements set forth in this paragraph in any subcontract under this Agreement.

Anti-Boycott Regulations.  Supplier shall comply with the Anti-Boycott Regulations of the United States, 15 Code of Federal Regulations, Part 369, promulgated under the U.S. Export Administration Act, 50 U.S.C. App. 2407.

Visas and Permits.  Supplier is responsible for obtaining appropriate visas and permits for all Personnel who are not US citizens and who may be required to travel to, and perform Services in, the US. Such visas and permits shall be in full compliance with applicable US immigration laws and regulations.  Upon request, Supplier shall provide Cardinal Health access to review the visas, permits, or other documentation establishing legal authorization of Personnel to work in the US. Supplier also shall complete any export licensing required during US visa processes and shall provide Cardinal Health with all license conditions before Personnel perform any Services.

Please make sure that you are aware of the Cardinal Health policy whether you receive or are planning to give gifts, it's important to keep our policies in mind regarding both Suppliers and Employees.

What do our policies say? - Here are some of the key policy provisions you'll want to keep in mind:

Meals - As a general rule, modest meals may occasionally be provided to customers or suppliers if the meal is in connection with a business meeting or presentation and occurs in a place and manner that supports the exchange of information.

Gifts to/from suppliers or other third parties - The policies are a little different for interactions with suppliers. Employees may accept from or provide to suppliers or other third parties who are not our customers or a healthcare professional items primarily for an employee's business use with a value of $100 or less. Receipt of food baskets or other perishable gifts are also permitted. If you receive a gift from a supplier that is not permitted and which cannot be returned, send the item to Community Relations for distribution to a charitable/non-profit organization.

Gift certificates - Cardinal Health employees may not give to or receive from suppliers gifts of any amount in cash or cash equivalents, like gift certificates.

Entertainment - Generally, employees may only participate in entertainment with third parties if each party pays for his or her own expenses. However, Cardinal Health may on occasion pay for the modest entertainment expenses of a supplier or other third party who is not a healthcare professional (e.g., physician, nurse, pharmacist, etc.). Entertainment that is offensive, degrading, exploitive or otherwise inappropriate is strictly prohibited, regardless of which party is paying for the entertainment.

State law - Cardinal Health policy is to comply with applicable law to the extent that applicable law requires a stricter standard than our policy.

Government - Most employees of governmental agencies, including but not limited to locally-, state- or federally-owned hospitals and clinics, members of Congress and their staffs and other elected officials are generally not allowed to accept meals, gifts or entertainment regardless of the value.

Cardinal Health will maintain policies and procedures for the reimbursement of reasonable travel and business expenses incurred by third parties with whom it does business (e.g., consultants, suppliers, etc.)(collectively referred to in this policy as "Suppliers").

Air Transportation

  • Class of Service - Cardinal Health's acceptable class of service for domestic air travelers is coach (economy) class. Contractors should book travel as far in advance as possible to take advantage of discounted airfare and the best possible availability of flight reservations.
  • Air Phone Expenses - Air phone charges are not reimbursable expenses.
  • Airport Parking - Long Term parking lots are those that are appropriate for parking and approved by Cardinal Health.

Rail Transportation

Class of Service - Cardinal Health's acceptable class of service for rail transportation is coach (economy) class.


  • Accommodations - Travelers should use standard single room accommodations at hotels and motels. The additional cost of room upgrades (e.g.; suite, executive floor, room with a view, etc.) is not reimbursable.
  • Hotel Reservations - All hotel reservations are to be at the lowest rate available when making reservations. In addition, the Traveler should always ask if lower rates are available while checking in at the hotel front desk, as rates and availability change frequently.
  • Non Reimbursable Hotel Expenses - Non reimbursable hotel expenses include, but are not limited to:
    • Hotel internet fees for services
    • Hotel telephone services
    • In-room movies and video games
    • Workout facility fees, spa fees, etc.
    • Additional in-room options, such as mini bar, snacks, etc.

Car Rental and Personal Vehicles

  • Vehicle Requirements - Travelers shall be responsible for either providing or renting their own vehicle. Travelers should rent vehicles no larger than an intermediate car (rental car terminology for a mid-sized car). Travelers may rent a full-sized car when plans include driving with more than two (2) people in the same car. Multiple travelers to one (1) location must share a vehicle. Rental cars must be returned to the rental agency with a full tank of fuel.
  • Vehicle Insurance - Travelers must provide their own automobile insurance at the minimum coverage limits required by the governing Cardinal Health agreement. Cardinal Health will not reimburse travelers for insurance coverage.
  • Tax, Shuttle, and Other Ground Transportation - The cost of taxis to and from places of business, hotels, airports, or railroad stations in connection with business activities is reimbursable.

Meals and Entertainment

Meal Costs - Cardinal Health reimburses Contractors for reasonable meal costs associated with overnight, out-of-town business trips. Meal charges for any one (1) day cannot exceed $50.00.

  • Alcohol is not reimbursable
  • Tips - Tips should be reported as part of the total meal cost. The commonly accepted rates for service are 15% - 17% for waiters/waitresses. The tip amount should be reasonable and customary for the event, geographic area, number in party, etc.

Other Reimbursable Expenses - If the reimbursement of an expense is not addressed in this policy, or if a traveler is unsure whether an expense is acceptable as a business expense, the traveler should contact the appropriate Cardinal Health Project Manager.

  • Cellular Phone Expenses - General cellular phone expenses are not reimbursable, unless specifically agreed to in the applicable contract document.
  • Laundry/Dry Cleaning/Valet - Laundry, dry cleaning and valet are personal expenses and are not reimbursable unless the Traveler is away from his/her normal business location base for more than five (5) consecutive nights; or, in the case of extenuating circumstances, such as lost or stolen luggage, business necessity, etc.
  • Parking and Tolls
  • Currency Conversion (Credit Card fees assessed when traveling outside country of origin)

Non Reimbursable Expenses - The following items are typically non-reimbursable expenses:

  • Upgrades to air or rail travel, car rentals, or hotel rooms not authorized or approved by Cardinal Health in advance.
  • Any lavish or extravagant expenditures, included upgraded rooms
  • Purchase of clothing, luggage, toiletries and other miscellaneous personal items
  • Expenditures for social purposes, or when used to conduct or discuss business matters which could have otherwise been handled during regular office hours
  • Entertainment of Cardinal Health employees, Cardinal Health contractors or other travelers
  • Supplemental travel insurance or additional auto rental insurance
  • Fines, penalties or legal fees incurred due to violation of laws
  • Personal entertainment or recreational expenses
  • Monetary payment to non-commercial establishments, such as friends or relatives homes for meals and/or lodging
  • Personal reading material, including newspapers and magazines, books, e-books, publications, and entertainment in both printed format and in electronic, CD and DVD media format.

Drug Screening and Background Checks - Subject to applicable laws, Approved Supplier shall perform a five (5) panel drug screen and criminal background investigation on all of its personnel providing services unescorted at Cardinal Health's facilities (Personnel) in accordance with Cardinal Health approval guidelines. This background investigation will consist of criminal convictions during the maximum period permitted by applicable state and federal law. Approved Supplier will use reasonable efforts to conduct the background investigation on the Personnel for each County in a State in which the Personnel has lived or worked during the maximum period of time permitted by applicable state and federal law. Additionally, subject to applicable laws, Cardinal Health may require copies of the drug screen and investigation results of any of the Personnel and to conduct periodic checks of such investigations to ensure compliance. If any Personnel have a lapse in assignment to Cardinal Health and/or a lapse in employment for thirty (30) days during the term of this Agreement, a new criminal background investigation and drug screen must be completed and the successful results of such must be confirmed in writing to Cardinal Health. Cardinal Health, or its authorized representative, shall have the right to examine, during ordinary business hours, all documents, records, reports, files, and other materials relative to this provision and maintained by Approved Supplier. To the extent permitted by applicable law, Approved Supplier agrees to comply, and shall instruct its Personnel to comply, with the reasonable request of Cardinal Health to perform, at Cardinal Health's expense, random five (5) panel drug screens of any Personnel at any time.

Identification Badges - Cardinal Health requires every person on Cardinal Health property to be positively identified with an identification badge. The senior site manager at each Cardinal Health facility is responsible for the development, implementation, and ongoing management of identification badge processes and procedures. Cardinal Health employees, third party vendors, and visitors are required to display an identification badge at all times while on company property.

Weapons Restriction - Cardinal Health, in compliance with applicable laws and regulations, prohibits individuals from possessing firearms, explosives or any other weapons on their person, in their work areas, locker rooms, or vehicles, except as noted below. This prohibition applies to all individuals on company premises or attending a Cardinal Health-sponsored event, and to any employee attending a vendor or customer event, regardless of the event's location.

Possession of firearms in private vehicles (United States only)
Unless permitted by applicable state laws and regulations, Cardinal Health prohibits employees or visitors from possessing firearms of any type, including but not limited to legally-owned firearms, within a private vehicle while on company property.