Code of Ethics and Conduct

Code of Ethics and Conduct

 

1. Build Trust and Credibility

The success of our Institution is dependent on the trust and confidence we earn from our patients who seek our care, their family members, colleagues and the community at large. We gain credibility by adhering to our commitments, displaying honesty and integrity and reaching the institution’s goals solely through honorable conduct. It is easy to say what we must do, but the proof is in our actions. Ultimately, we will be judged on what we do.

When considering any action, it is wise to ask:

• Will this benefit our Patients?
• Will this build trust and credibility for NU Hospitals?
• Will it help create a working environment in which NU Hospitals can succeed over the long term?
• Is the commitment I am making one I can follow through with?

If the answer is “yes” to all the above questions, the action can be considered as one that builds trust and credibility.

2. Respect for the Individual

NU Hospitals believes in fostering an atmosphere where all our patients, their family, stakeholders, team members and associates are treated with dignity and respect.

NU Hospitals is an equal employment/affirmative action employer and is committed to providing a workplace that is free of discrimination of all types from abusive, offensive or harassing behavior. Any team member who feels harassed or discriminated against should report the incident to his or her manager or to human resources. Harassment of any nature is a zero tolerance offence.

3. Create a Culture of Open and Honest Communication

At NU Hospitals everyone should feel comfortable to speak his or her mind, particularly with respect to ethical concerns. Managers have a responsibility to create an open and supportive environment where team members feel comfortable speaking their mind. We all benefit tremendously when team members exercise their power to prevent mistakes or wrongdoing by asking the right questions at the right time.

NU Hospitals will investigate all reported instances of questionable or unethical behavior. In every instance where improper behavior is found to have occurred, the institution will take appropriate action. We will not tolerate retaliation against team members who raise genuine ethical concerns in good faith.

 

 

NU Hospitals’ whistleblower policy is as follows:

If any team member notices/ comes across information of any suspicious activity, illegal transaction or anything that is in violation of the institution’s values, they are encouraged, in the first instance, to address such issues with their managers or the HR Partner, as most problems can be resolved swiftly. If for any reason that is not possible or if a team member is not comfortable raising the issue with his or her manager or HR Partner, NU Hospitals’Chief People Officer, Group Medical Director, Managing Director, and Chairman operate with an open-door policy and could be approached to address issues. The recipient of such information is obligated to keep the source of such information confidential.

4. Set Tone at the Top

Management has the added responsibility for demonstrating, through their actions, the importance of this Code. In any institution, ethical behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example. Again, ultimately, our actions are what matters.

To make our Code work, managers must be responsible for promptly addressing ethical questions or concerns raised by team members and for taking the appropriate steps to deal with such issues. Managers should not consider team members’ ethical concerns as threats or challenges to their authority, but rather as another encouraged form ofcommunication. At NU Hospitals, we want the ethics dialogue to become a natural part of daily work.

5. Uphold the Law

NU Hospitals’ commitment to integrity begins with complying with laws, rules and regulations where we do business. Further, each of us must have an understanding of the Hospitals’ policies, laws, rules and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or NU Hospitals’ policy, we should seek the advice from the reporting manager, Unit Head or HR Partner. We are responsible for preventing violations of law and for speaking up if we see possible violations.

6. Competition

NU Hospitals is dedicated to ethical, fair and vigorous competition. We will provide services based on their merit, superior qualityand competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for NU Hospitals or the sales of its services, nor will we engage or assist in unlawful boycotts of any nature.

7. Proprietary Information

NU Hospitals will not acquire or seek to acquire improper means of a patient’s, associate’s or competitor’s trade secrets or other proprietary or confidential information. Team members will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property, policies or protocols of NU Hospitals, its patients or its associates.

 

 

8. Selective Disclosure

Team members will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals or otherwise) any material nonpublic information with respect to NU Hospitals, its patients,its business operations, plans, financial condition, results of operations or any development plan. Team members should be particularly vigilant when making presentations or proposals to external parties to ensure that our presentations do not contain nonpublic information.

 

9. Health and Safety

NU Hospitals is dedicated to maintaining a healthy environment. Any concerns related to health and safety at work place can be promptly addressed with the HR department.

 

10. Avoid Conflicts of Interest

 Conflicts of Interest

We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of NU Hospitals may conflict with our own personal or family interests. We owe a duty to NU Hospitals to advance its legitimate interests when the opportunity to do so arises. We must never use NU Hospitals property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with NU Hospitals.

Here are some other ways in which conflicts of interest could arise:

1. Being employed (self or a family member) by, or acting as a consultant to, patient(s) or their relatives, a competitor or potential competitor, supplier or contractor, regardless of the nature of the employment or association, while you are employed with NU Hospitals.

2. Hiring or supervising family members or closely related people.

3. Serving as a board member for an outside commercial company or organization.

4. Owning or having a substantial interest in a competitor, supplier or contractor.

5. Having a personal interest, financial interest or potential gain in any transaction.

6. Placing company business with a firm owned or controlled by a NU Hospitalsteam member or his or her family.

7. Accepting gifts, discounts, favors or services from a patient/patient family, competitor or supplier.

 

 

 

Determining whether a conflict of interest exists is not always easy to do. Team members with a conflict of interest question should seek advice from their manager, Unit Head or HR.

Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, team members must seek review from their Managers, Unit Head or the HR department.

11. Gifts, Gratuities and Business Courtesies, Financial Transactions

NU Hospitals is committed to competing solely on the merit of our service excellence, expert advice and ethical treatment. We should avoid any actions that create a perception that favorable treatment of outside entities by NU Hospitals was sought, received or given in exchange for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment, money or other benefits from colleagues,patients, persons or companies with whom NU Hospitals does or may do business. We will neither give nor accept business courtesies that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or polices of NU Hospitals, or would cause embarrassment or reflect negatively on NU Hospitals’ reputation.

Team members with questions about accepting money, gifts, gratuities or business courtesies should talk to their managers or the HR department before taking a decision on accepting any gifts or courtesies.

Any financial transaction or dealings amongst team members of NU Hospitals is strictly prohibited too and is considered as a zero tolerance offence.

Any financial transaction or dealings between team members of NU Hospitals& Patients/ Patient Family/ Associates/Vendors of NU Hospitals is strictly prohibited too and is considered as a zero tolerance offence.

 

12. Offering Business Courtesies

Any team member who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon NU Hospitals.A team member may never use personal funds or resources to do something that cannot be done with NU Hospitals’ resources. Accounting for business courtesies must be done in accordance with approved company procedures.

 Further, the management (Chairman, Managing Director, Group Medical Director, Chief People Officer or Unit Head) may approve other courtesies, including meals, refreshments or entertainment of reasonable value, provided that:

• The practice does not violate any law or regulation or the standards of conduct of NU Hospitals.

• The business courtesy is consistent with industry practice, is infrequent in nature and is not lavish.

 

 

• The business courtesy is properly reflected on the records of NU Hospitals/ disclosed voluntarily and approved by authorities (Unit Head Or Chief People Officer).

 

13. Set Metrics and Report Results Accurately

 Accurate Public Disclosures

NU Hospitals will make certain that all disclosures made in financial reports and public documents are full, fair, accurate, timely and understandable. This obligation applies to all team members, including all financial executives, with any responsibility for the preparation for such reports, including drafting, reviewing and signing or certifying the information contained therein. No business goal of any kind is ever an excuse for misrepresenting facts or falsifying records.

Team members should inform the Chief People Officeror the Managing Director if they learn that information in any filing or public communication was untrue or misleading at the time it was made or if subsequent information would affect a similar future filing or public communication.

 

 Corporate Recordkeeping

We create, retain and dispose of our company records as part of our normal course of business in compliance with all our policies and guidelines, as well as all regulatory and legal requirements.

All corporate records must be true, accurate and complete, and company data must be promptly and accurately entered in our books in accordance with NU Hospitals’ and other applicable accounting principles.

We must not improperly influence, manipulate or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of the institution’s books, records, processes or internal controls.

14. Accountability

Each of us is responsible for knowing and adhering to the values and standards set forth in this Code and for raising questions if we are uncertain about company policy. If we are concerned whether the standards are being met or are aware of violations of the Code, we must contact the HR department immediately.

15. Confidential and Proprietary Information

Integral to NU Hospitals’ business success is our protection of confidential company information, as well as nonpublic information entrusted to us. Confidential and proprietary information includes such things as pricing and financial data, Hospital’s policy & Protocols, patients’ names/addresses or nonpublic information about other companies, including current or potential supplier and vendors. We will not disclose confidential and nonpublic information without a valid business purpose and proper authorization.

 

 

16. Use of NU Hospitals’ Resources

NU Hospitals’ resources, including time, material, equipment and information, are provided for official use.

Team members and those who represent NU Hospitals are trusted to behave responsibly and use good judgment to conserve the institution’s resources. Managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use.

Office equipment such as computers, copiers, mobile phones, any other gadget/ device shall not be used in the conduct of an outside business or in support of any religious, political or other outside daily activity. We will not solicit contributions nor distribute non-work related materials during work hours.

In order to protect the interests of NU Hospitals’ and its team members, NU Hospitals reserves the right to monitor or review all data and information contained on an employee’s company-issued computer or electronic device, the use of the Internet or intranet. We will not tolerate the use of official resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate.

Questions about the proper use of company resources should be directed to the reporting manager or Unit Head.

 

17. Media Inquiries

From time to time,team members may be approached by reporters and other members of the media. In order to ensure that we speak with one voice and provide accurate information about the Institution, team members should direct all media inquiries to the Unit Head of their facility. No one may issue a press release without first consulting with the Unit Head of their facility.

 

18. Do the Right Thing, Always

Several key questions can help identify situations that may be unethical, inappropriate or illegal. Ask yourself:

• Is this the right thing to do?

•Does what I am doing comply with NU Hospitals’ guiding principles, values, Code of Conduct and policies?

• Have I been asked to misrepresent information or deviate from normal procedure?

• Would I feel comfortable describing my decision at a staff meeting?

• How would it look if it made the headlines?

• Am I being loyal to my patients, my family, my Institution and myself?

NU Hospitals takes seriously the standards set forth in the Code, and violations are cause for disciplinary action up to and including termination of employment.

 

Summary:

• Build Trust and Credibility
• Respect for the Individual
• Create a Culture of Open and Honest Communication
• Set Tone at the Top
• Uphold the Law
• Competition
• Proprietary Information
• Selective Disclosure
• Health and Safety
• Avoid Conflicts of Interest
• Gifts, Gratuities and Business Courtesies, Financial transactions
• Offering Business Courtesies
• Set Metrics and Report Results Accurately
• Accountability
• Confidential and Proprietary Information
• Use of NU Hospitals’ Resources
• Media Inquiries
• Do the Right Thing, Always