Corporate Policies
Created January 1, 2023
GROW Counseling Network (GCN) is committed to operating with integrity, protecting the people we serve, and treating our team and our network of clinicians fairly. This document sets out the policies that guide how we do business. It is provided for reference by current and prospective employer clients, partners, and members of our counselor network.
Business Integrity
Anti-Corruption and Anti-Bribery
GCN conducts business with integrity and prohibits bribery and corruption in any form. GCN Personnel do not, directly or indirectly, offer, give, request, or accept any bribe, kickback, or improper payment in connection with GCN business. This applies regardless of the size or form of the payment, and applies to interactions with private parties and with government officials. Gifts and hospitality are permitted only where they are modest, infrequent, and customary, and never in cash. This policy is intended to comply with the U.S. Foreign Corrupt Practices Act and other applicable anti-bribery laws.
Conflicts of Interest
GCN Personnel are expected to act in the best interests of GCN and the individuals it serves. Personal, financial, family, or outside business interests that could influence GCN business decisions must be disclosed at the start of an engagement with GCN, and again whenever a new conflict arises. Counselors must additionally comply with all dual-relationship and conflict-of-interest requirements of their state licensing board's ethics code. Disclosed conflicts are reviewed and managed by the CEO. Common management steps include recusal, reassignment of a Participant to a different counselor, or restrictions on access to information.
Anti-Fraud
GCN has zero tolerance for fraud. Session billing is submitted through a structured intake system that records counselor, Participant control number, session date, and location. Participant satisfaction surveys are sent at intake, every five sessions, and at termination, and include questions that allow GCN to cross-validate that the sessions billed were actually delivered. Discrepancies are investigated. Substantiated fraud results in immediate removal from the network, forfeiture of unpaid amounts, recovery of paid amounts where appropriate, reporting to the counselor's licensing board where required, and referral to law enforcement where appropriate.
Anti-Money Laundering
GCN does not accept cash. All payments to and from GCN are conducted by traceable electronic methods (ACH, wire transfer, or business check). Counselor and vendor banking information is verified before any payment is issued, and changes to banking information require independent verification. GCN maintains records of all financial transactions consistent with applicable law and good business practice.
Fair Competition
GCN competes on the quality of its clinical network, the strength of its service, and the value it delivers to Employer Clients. GCN does not engage in price-fixing, market or customer allocation, bid rigging, group boycotts, or the sharing of competitively sensitive information with competitors. GCN's interactions with peer organizations (for example, referrals, professional associations, and continuing education events) are conducted in a manner consistent with applicable competition law.
Responsible Marketing
GCN's external statements about its services must be accurate and substantiated. Statistical claims, such as satisfaction scores, network size, utilization rates, and outcomes, are supported by current internal data. GCN does not guarantee clinical outcomes. Participant feedback is used in marketing only in anonymized form, only with information that could not identify the Participant, and only in a manner consistent with HIPAA and any applicable Business Associate Agreement. Naming an Employer Client in marketing requires that client's prior written consent.
People and Culture
Equal Opportunity, Human Rights, and Labor Practices
GCN provides equal employment and contracting opportunities to all qualified individuals without regard to race, color, religion, sex (including pregnancy, sexual orientation, and gender identity), national origin, age, disability, genetic information, veteran status, marital status, or any other category protected by applicable federal, state, or local law. GCN pays employees and contractors fairly for the work performed, complies with applicable wage and hour laws, does not use forced or child labor, and requires the same of its vendors and partners. GCN provides reasonable accommodation to qualified individuals with disabilities and to employees with religious observance needs.
Anti-Discrimination and Anti-Harassment
GCN maintains a working environment free from discrimination, harassment, and retaliation. Harassment, including sexual harassment, bullying, and intimidation, is prohibited. Concerns can be raised directly to the CEO, and where the concern involves the CEO, to legal counsel of the Company. GCN promptly investigates all good-faith reports. Substantiated violations result in corrective action up to and including termination of employment or contractor engagement. Retaliation against any person who raises a concern in good faith is itself a violation of this policy.
Employee Health, Safety, and Wellbeing
As a mental-health-focused company, employee wellbeing is central to who we are. GCN supports flexible and remote work arrangements where consistent with role requirements, provides competitive paid time off, and provides mental health support to all employees and contractors.
Diversity, Equity, and Inclusion
GCN is intentionally diverse across our internal team and our counselor network. We recruit for diversity across race, ethnicity, gender identity, sexual orientation, faith tradition, age, and lived experience, both because it is the right thing to do and because the populations we serve need representative care options. Our progress is reviewed in our annual operations review.
Employee Development
GCN supports professional growth for all members of its team. We provide an annual professional development budget for staff and free continuing education for our entire counselor network as part of the value we offer them. Peer consultation and clinical learning forums are available to network counselors.
Participant and Client Protection
Confidentiality
Confidentiality is the foundation of our service. Counselors are independently licensed and bound by their state board's confidentiality rules, their professional ethics code, and HIPAA where applicable. GCN does not collect, store, or transmit clinical session content. The information GCN collects from counselors is limited to billing data: counselor name, Participant control number, session location, and date of session.
Participants are referenced in any reporting to an Employer Client by a GCN-internal control number, never by name. Reporting to an Employer Client is provided in anonymized, aggregated form, with small-cell suppression to prevent inferred identification.
At intake, every Participant signs a Patient Acknowledgement and Bill of Rights that explains GCN's role, the relationship with the Employer Client, GCN's responsibilities to the Participant, and confidentiality and its limits.
Information Security
GCN handles sensitive information about Participants, counselors, and Employer Clients. Data is encrypted at rest and in transit using current industry-standard methods. Multi-factor authentication is required for access to systems containing confidential or HIPAA-protected information. Access is granted on a least-privilege basis, reviewed periodically, and revoked promptly upon termination of employment or contractor engagement. Business Associate Agreements (BAAs) are executed with any vendor that creates, receives, maintains, or transmits Protected Health Information on behalf of GCN.
GCN does not currently hold ISO 27001 or SOC 2 certification. Our information security program is anchored in HIPAA, state licensing board requirements, and the professional ethics codes that bind every counselor in the network.
Incident Response
Any suspected or actual security or confidentiality incident must be reported to the CEO without delay, and in any event within twenty-four hours of discovery. GCN's response process covers immediate containment, assessment of scope and impact (including any HIPAA breach analysis where Protected Health Information may have been involved), notification to affected individuals and authorities where required by law or contract, remediation of the root cause, and internal documentation of the incident and corrective action.
Environmental Responsibility
GCN operates primarily as a remote organization. We do not maintain a manufacturing operation, we do not ship physical product, and our administrative footprint is small. Travel is limited and most client engagement is virtual, which keeps our environmental impact correspondingly low. GCN does not currently hold a Net Zero or Science Based Targets initiative (SBTi) target. We are open to developing measurable environmental commitments where these support our Employer Client relationships.
Contact
Questions about any of these policies can be directed to:
Wendy Dickinson Ragland, Ph.D.
Founder and Chief Executive Officer
GROW Counseling Network, LLC
2964 Peachtree Road NW, Suite 760, Atlanta, GA 30305