Quality, Affordable and Accessible

CODE OF CONDUCT

Sinophi Healthcare Code of Conduct

Mission Statement

To be recognized for our high standards of service, professionalism and quality of care in delivering healthcare services.

To nurture working environments which attract, motivate, develop and retain the best people in our industry. 

To be honest, open, fair and transparent in all we do, for the mutual benefit of our patients, our team members and our stakeholders.

To be a leading provider of quality healthcare in China.

Code Of Conduct

Introduction

As a pioneering international company engaging in hospital investment and management in China and in the distribution of world leading proton therapy technology, we recognize that we have to set the highest standards of ethical business practice.

Our Code of Conduct sets out clear standards of behaviour that we expect our employees to demonstrate in dealing with colleagues and those external to the Company such as customers, suppliers, shareholders and other stakeholders.

Employees

As a Company operating in the health sector our employees are key to our continued success. We respect and value the individuality and diversity that every employee brings to the business and seek to create a positive, open working environment wherever we operate.

• We are committed on basing relations with employees on respect for the dignity of the individual and fair treatment for all.
• We aim to recruit and promote employees on the basis of suitability for the job, without discrimination.
• We aim to foster effective communication to enable all our employees to perform their work effectively.
• We place the highest priority on the health and safety of our employees and the safety of the environment in which they work.
• We do not tolerate any form of discrimination or sexual, physical, mental or other harassment of any kind towards our employees, whether from our own staff or others.
• We operate fair and just remuneration policies.
• We require any employee with a potential conflict of interest to disclose it to their line manager.
• We operate in an environment of trust and as such we do not tolerate any fraudulent or dishonest behaviour by our employees either within the Group or in dealing with other stakeholders.

Customers

We are committed to delivery of a high quality service to our clients and customers, our reputation and the continued relationships with clients depend on it.

• The quality and safety of the services we provide, and that of our products and processes is paramount and must never be compromised.
• We aim to provide a high level of client and customer services at all times.
• All customer and client information is treated as confidential.
• We never deliberately give inadequate or misleading descriptions of our products and services.
• No employee may offer or receive or influence others to offer or receive any money or material gift that could be construed as a bribe.

Investors

The Company’s success is built upon the trust and confidence of those who invest in us, and we are committed to protecting their long term investment.

• We are committed to a high standard of corporate governance and accountability.
• Our accounting statements will be true, timely, complete and material and will be made available in an easily understandable form.

Suppliers and Sub-Contractors

We seek to establish mutually beneficial relationships with all our suppliers and encourage them to match our high standards in respect of working conditions, trading practices, health and safety and environmental protection.

• We treat our suppliers and sub-contractors honestly and fairly.
• No employee may offer or receive, or influence others to offer or receive, any money or material gift that could be construed as a bribe or influence.
• We endeavour to ensure that we are not exploited directly or indirectly by requests to make facilitation payments.
• All information concerning the Company and its suppliers is to be treated as confidential.
• We do not work with companies that infringe the law or endanger our reputation.

Governments and the Wider Community

Our success is dependent on compliance with legal constraints together with sensitivity to local customs and conventions governing business relationships.

• We endeavour to ensure that we are not exploited for the purposes of money laundering, drug trafficking or tax evasion.
• We respect the law, traditions and cultures of the countries where we operate. When there is a conflict between local custom and the principle and values set out in this Code, employees acting on our behalf must be guided by the Code.
• We are committed to doing our business in a way that is as environmentally friendly as possible.

Competitors

We are committed to doing business fairly. In all our business dealings we will compete vigorously, but we will also comply with all the laws and regulations protecting the integrity of the market place.

• We will not make false statements about competitors or their services.
• We will not steal or misuse competitors’ trade secrets.
• We will not pay bribes to help the company or hurt a competitor.

Compliance 

Employees of the Company and its affiliates (even those residing outside of the United Kingdom and the United States of America) must comply with the U.K. Bribery Act 2010 and the U.S. Foreign Corrupt Practices Act of 1987, irrespective of whether or not these statutes are applicable to them, and they must also comply with all other applicable laws for the prevention of anti-bribery and corruption.  In general, these laws make it unlawful to bribe, or offer to bribe, any person in connection with any commercial arrangement, including both government officials and private persons.  They also make it unlawful for any Sinophi employee to accept or request a bribe in connection with any commercial transaction. The same restrictions apply to all distributors and agents engaged by Sinophi.  So-called grease or facilitation payments are strictly prohibited.

All employees must be familiar with and comply with their obligations as described above, and in particular the Company’s anti-bribery and corruption policies and procedures applicable to them.

Escalation Process

• If employees become aware of any incident or practice or breach of this code they should raise it in the first instance with their line manager.
• If for any reason the employee feels they can not raise it with their line manager, then the matter should be raised with their line manager’s manager or the Chairman or CEO. as appropriate

The Company Chairman’s decision on the interpretation of this Code is final.

Sinophi Healthcare Limited – June 2014