Policy for Ethics and Code of Conduct Template

1. Objective

[Company Name] is proud of the values with which it conducts its business activities in order to achieve its vision and mission. It continues to uphold the highest levels of business ethics and personal integrity in all types of transactions and interactions.

In this perspective, this Code of Business Conduct and Ethics serves as guiding principles to protect and promote organizational integrity and to enhance [Company Name]'s ability to achieve its organizational vision and mission.

2. Scope

This Code of Business Conduct and Ethics applies to all directors, officers, and employees, including those of each subsidiary of [Company Name].

Such directors, officers, and employees are referred to herein collectively as the "Covered Parties".

3. Vision & Mission

3.1 Our Vision

Our vision is to create the highest quality healthcare delivery ecosystem to improve the country's overall health and quality of life.

Our promise to deliver such an ecosystem does not focus on simply providing good equipment and facilities, but also on staffing our hospitals with internationally accredited, highly skilled and qualified doctors, well-trained nurses, utilizing an advanced electronic method of maintaining and storing medical records, and implementing internationally practiced medical protocols, to name a few.

3.2 Our Mission

Our mission is to take a quantum leap forward to provide our community of patients with innovative and compassionate care in a comfortable environment.

We offer our patients fully equipped surgical theatres that are staffed and supervised by some of the leading medical practitioners in the world.

4. Standards of Conduct & Ethics

4.1 Conflicts of Interest

• A conflict of interest exists when a person's private interest interferes in any way with the interests of the company. A conflict can arise when a Covered Party takes actions or has interests that may make it difficult to perform his or her work for the company objectively and effectively. Conflicts of interest may also arise when a Covered Party, or members of his or her family, receive improper personal benefits as a result of their position. Loans to, or guarantees of obligations of, Covered Parties and their family members may create conflicts of interest. It is almost always a conflict of interest for a Covered Party to work simultaneously for a competitor, customer, or supplier.
• All employees shall disclose any material transaction or relationship that could reasonably be expected to give rise to such a conflict to the CEO & HR Head. No action may be taken with respect to such transaction or party unless and until it has been approved by the CEO & HR Head.
• The Covered Parties shall always adhere to the Anti-Bribery, Anti-Corruption, Gifts, and Entertainment Policy as issued and approved by the CEO & HR Head from time to time.

4.2 Corporate Assets & Opportunities

Covered Parties are prohibited from taking for themselves opportunities discovered through the use of corporate property, information, or position without the consent of the Board of Directors. No Covered Party may use corporate property, information, or position for improper personal gain, and no employee may compete with the company directly or indirectly. Covered Parties owe a duty to [Company Name] to advance its legitimate interests whenever possible.

4.3 Fair Dealing

Covered Parties shall behave honestly and ethically at all times and with all people. They shall act in good faith, with due care, and shall engage only in fair and open competition, treating ethically competitors, suppliers, customers, and colleagues. No Covered Party should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair practice.

4.4 Insider Trading

Covered Parties who have access to confidential information are not permitted to use or share that information for securities trading purposes ("insider trading") or for any other purpose except the conduct of [Company Name]'s business. All non-public information should be considered confidential. It is always illegal to trade in [Company Name]'s securities while in possession of material, non-public information, or to "tip" such information to others.

4.5 Confidentiality

Covered Parties must maintain the confidentiality of confidential information entrusted to them, except when disclosure is authorized or required by law. Confidential information includes all non-public information that might be of use to competitors or harmful to [Company Name] or its customers if disclosed. It also includes information entrusted by suppliers and customers, including the medical records of patients. The obligation to preserve confidential information continues even after employment ends.

4.6 Protection & Proper Use of Assets

• All Covered Parties should endeavor to protect [Company Name]'s assets and ensure their efficient use. Theft, carelessness, and waste directly impact [Company Name]'s profitability. Any suspected incident of fraud or theft should be reported immediately. Company equipment should not be used for non-business purposes, though incidental personal use is permitted.
• The obligation of Covered Parties to protect company assets includes its proprietary information.
• Proprietary information includes intellectual property such as trade secrets, patents, trademarks, copyrights, business plans, marketing ideas, databases, and financial data. Unauthorized use or distribution of this information violates [Company Name] policy and may also be illegal.

4.7 Compliance with Laws, Rules & Regulations

• Obeying the law, both in letter and in spirit, is the foundation on which [Company Name]'s ethical standards are built.
• Covered Parties shall comply with all applicable laws, rules, and regulations at all levels of government. While not all Covered Parties are expected to know every detail, they must seek advice when unsure — from supervisors, HODs, the CFO, or HR Head.

4.8 Timely & Truthful Disclosure

Covered Parties involved in preparing reports and documents for authorities or regulators must ensure that such disclosures are full, fair, accurate, timely, and understandable. They must provide thorough and accurate financial data and must not conceal or falsify information or mislead auditors or investors.

5. Waivers

Any waiver of this Code may be made only by [Company Name]'s CEO & HR Head and will be promptly disclosed as required by law.

6. Violations of Code

6.1 Reporting Known or Suspected Violations

Any known or suspected violation of this Code must be reported immediately in accordance with the Whistleblowing Policy. No retaliatory action will be permitted against anyone making such a report in good faith.

6.2 Accountability for Violations

If it is determined that this Code has been violated — either directly, by failure to report, or by withholding information — the offending Covered Party may face disciplinary action, up to and including dismissal. Violations may also result in criminal penalties or civil liabilities. All Covered Parties are expected to cooperate in internal investigations of misconduct.

7. Compliance Procedures

We must all work together to ensure prompt and consistent action against violations of this Code. In some situations, however, it is difficult to know if a violation has occurred. Keep these steps in mind:

• Make sure all facts are gathered before taking action.
• Ask: What am I being asked to do? Does it seem unethical or improper?
• Clarify responsibilities and discuss with colleagues if needed.
• Discuss the problem with your supervisor.
• Seek help from [Company Name] resources — HR Head or CEO — if supervisor guidance is inappropriate or inadequate.
• Report ethical violations according to the Whistleblowing Policy.
• If in doubt, always seek appropriate guidance to avoid any violation.

8. Disclaimer

• The policy and procedures in this document may change at any time, at the sole discretion of [Company Name]'s Management, without prior notice. No statement or promise by a supervisor or manager may alter this policy.
• This document should be read alongside Local Labor Laws, which take precedence where applicable.
• This policy is effective from the date of issuance and supersedes all previous procedures or understandings on this subject.

Subject: Acknowledgment of Ethics and Code of Conduct Policy

Dear [HR Director/Manager Name],

I, [Employee Full Name], acknowledge that I have received, carefully read, and fully understand the [Company Name] Ethics and Code of Conduct Policy dated [Policy Date]. I have had adequate opportunity to review this policy and ask questions regarding any provisions that required clarification.

I understand that this policy establishes the ethical standards and behavioral expectations for all employees and represents the core values of our organization. I commit to conducting myself in accordance with all provisions outlined in this policy, including:

- Maintaining confidentiality and protecting sensitive company information

- Avoiding conflicts of interest and disclosing potential conflicts promptly

- Treating all colleagues, clients, and stakeholders with respect and dignity

- Using company resources responsibly and only for authorized purposes

- Reporting suspected violations through appropriate channels

- Cooperating fully with any investigations into policy violations

- Upholding the organization's reputation in all professional interactions

I understand that compliance with this policy is a condition of my employment and that violations may result in disciplinary action, up to and including termination. I also acknowledge my responsibility to report observed violations and understand that the organization prohibits retaliation against anyone who reports concerns in good faith.

Should I have questions or require guidance regarding any ethical matter, I will consult with my supervisor, the Human Resources department, or the Ethics Hotline at [contact information].

Respectfully,

[Employee Signature]

[Printed Name]

[Employee ID Number]

[Department]

[Date]

Subject: Confidential Ethics Concern Report

To the Ethics Committee / HR Department,

I am submitting this report to bring to your attention a matter that may constitute a violation of our organization's Ethics and Code of Conduct Policy. I request that this report be handled with appropriate confidentiality and discretion.

NATURE OF CONCERN:

[Select category: Conflict of Interest / Harassment / Discrimination / Fraud / Theft / Safety Violation / Confidentiality Breach / Misuse of Resources / Other]

INCIDENT DETAILS:

Date(s) of Occurrence: [Specific dates or timeframe]

Location: [Department, building, or specific area]

Individuals Involved: [Names or descriptions of those involved]

Witnesses: [Names of anyone who observed the incident, if applicable]

DESCRIPTION OF EVENTS:

[Provide a detailed, factual account of what occurred. Include specific behaviors, statements, actions, or patterns that constitute a policy violation. Focus on observable facts rather than assumptions or interpretations. Be as specific as possible regarding dates, times, locations, and exact words or actions.]

SUPPORTING DOCUMENTATION:

[List any evidence such as emails, photographs, documents, recordings, or other materials that support this report. If attaching files, reference them here.]

PREVIOUS REPORTS OR COMPLAINTS:

[Indicate if this matter has been reported before, to whom, and what action was taken, if known]

IMPACT ON WORKPLACE:

[Describe how this situation has affected you, other employees, departmental operations, or the organization]

REQUESTED ACTION:

[Specify if you are requesting investigation, intervention, policy clarification, or other specific outcomes]

CONTACT PREFERENCE:

I prefer to: [Remain anonymous / Be contacted for follow-up / Receive investigation outcome notification]

If you need additional information, I can be reached at: [Contact information, if not remaining fully anonymous]

I am submitting this report in good faith and request that appropriate action be taken to address this matter and prevent future occurrences.

Submitted by: [Your name or "Anonymous Reporter"]

Submission Date: [Date]

Reference Number: [If provided by reporting system]

Subject: Request for Clarification on Ethics Policy [Specific Topic]

Dear [Ethics Officer/HR Manager Name],

I am writing to request clarification regarding a provision in our Ethics and Code of Conduct Policy. I want to ensure that I fully understand the policy requirements and am acting in complete compliance with organizational standards.

POLICY SECTION REQUIRING CLARIFICATION:

[Reference specific section number, page, or topic from the policy]

MY QUESTION OR CONCERN:

[Clearly state what aspect of the policy is unclear or what scenario you need guidance on]

CONTEXT OF MY INQUIRY:

[Provide relevant background about why you're asking. Describe the situation, business need, or circumstances that prompted your question without revealing confidential information if not necessary]

SPECIFIC SCENARIO:

[If applicable, describe a hypothetical or actual situation you're trying to navigate ethically]

I have reviewed the relevant policy sections but would appreciate official guidance to ensure I proceed appropriately. I am committed to maintaining the highest ethical standards and want to make certain my actions align fully with organizational expectations.

Could we schedule a brief meeting to discuss this matter, or would you prefer to provide written guidance? I am available at your convenience and appreciate your assistance in helping me navigate this situation properly.

Thank you for your time and attention to this matter.

Professionally,

[Your Name]

[Title]

[Department]

[Contact Information]

[Date]

Subject: Response to Ethics Complaint [Reference Number]

Dear [Ethics Committee/HR Director Name],

I am writing in response to the ethics complaint filed against me on [Date] regarding [Brief description of allegation]. I take this matter very seriously and appreciate the opportunity to provide my perspective on the situation.

ACKNOWLEDGMENT:

I acknowledge that I have been informed of the complaint and understand the specific allegations being made. I have reviewed the relevant sections of our Ethics and Code of Conduct Policy referenced in the complaint.

MY ACCOUNT OF EVENTS:

[Provide your detailed, factual version of what occurred. Be specific about dates, times, locations, and circumstances. Address each allegation directly.]

RELEVANT CONTEXT:

[Explain any circumstances, organizational practices, prior approvals, or other context that is relevant to understanding the situation]

SUPPORTING EVIDENCE:

[Reference any documentation, communications, witnesses, or other evidence that supports your account]

ACKNOWLEDGMENT OF POLICY:

[If applicable, acknowledge if you made an error in judgment or violated policy, or alternatively, explain why you believe your actions were compliant]

CORRECTIVE ACTIONS TAKEN:

[If applicable, describe any steps you have already taken to address the concern or prevent future occurrences]

I am fully committed to cooperating with the investigation process and am available to meet with investigators, provide additional information, or answer any questions you may have. I respect the organization's commitment to maintaining ethical standards and appreciate fair and thorough consideration of this matter.

Please let me know what additional information or documentation would be helpful as you review this complaint.

Respectfully submitted,

[Your Name]

[Title]

[Employee ID]

[Department]

[Date]

[Signature]

Subject: Important Update to Ethics and Code of Conduct Policy

Dear Team Members,

I am writing to inform you of important updates to our Ethics and Code of Conduct Policy, effective [Effective Date]. These revisions reflect our ongoing commitment to maintaining the highest ethical standards and adapting to evolving workplace dynamics and regulatory requirements.

SUMMARY OF KEY CHANGES:

[List the most significant updates, such as:]

- New provisions regarding social media and online conduct

- Enhanced protections for whistleblowers

- Updated conflict of interest disclosure requirements

- Clarified guidelines on accepting gifts and entertainment

- New procedures for reporting ethics concerns

- Expanded anti-discrimination and harassment protections

WHY THESE CHANGES WERE MADE:

[Briefly explain the rationale, such as new regulations, incidents that highlighted gaps, employee feedback, or industry best practices]

WHAT YOU NEED TO DO:

1. Review the updated policy thoroughly (attached and available on [location])

2. Complete the online training module by [Deadline Date]

3. Sign and submit the new acknowledgment form by [Deadline Date]

4. Direct any questions to [Contact Person/Department]

The updated policy represents our collective commitment to creating an ethical, respectful, and compliant workplace. All employees are expected to familiarize themselves with these changes and integrate them into their daily work practices.

Mandatory training sessions will be held on the following dates:

[List session dates, times, and locations or virtual meeting links]

If you have questions about any aspect of the updated policy or need clarification on how these changes apply to your specific role, please don't hesitate to reach out to the Human Resources department or Ethics Office.

Thank you for your continued commitment to upholding our organization's values and ethical standards.

Sincerely,

[Senior Leader Name]

[Title]

[Company Name]

[Date]

Subject: Certification of Ethics and Code of Conduct Training Completion

Dear [HR Manager/Training Coordinator],

This message confirms that I have successfully completed the mandatory Ethics and Code of Conduct training on [Completion Date]. I am providing this certification as required by organizational policy.

TRAINING DETAILS:

Course Title: [Full name of training program]

Completion Date: [Date]

Duration: [Hours]

Training Method: [Online module / In-person session / Webinar / Workshop]

Instructor/Facilitator: [Name, if applicable]

Certificate/Confirmation Number: [If provided]

I confirm that I have:

- Attended/completed all required training sessions or modules

- Reviewed all training materials, case studies, and scenarios

- Passed any required assessments or quizzes with a score of [Score]%

- Understood the ethical standards and expectations outlined in the training

- Asked questions and received satisfactory answers to any areas of uncertainty

KEY TAKEAWAYS FROM THE TRAINING:

[Optional: Briefly list 2-3 key learnings or insights gained]

I understand that this training is part of my ongoing professional development and commitment to maintaining ethical standards in my work. I am prepared to apply these principles in my daily responsibilities and to seek guidance when facing ethical dilemmas.

Please file this certification in my training records. If you require any additional documentation or have questions regarding my training completion, please let me know.

Thank you.

Best regards,

[Your Name]

[Employee ID]

[Department]

[Date]

[Signature, if required]

Subject: Disclosure of Potential Conflict of Interest

Dear [Ethics Officer/Supervisor Name],

In accordance with our organization's Ethics and Code of Conduct Policy, I am disclosing a potential conflict of interest that may affect my professional duties and responsibilities. I believe in transparent communication and want to ensure full compliance with organizational ethical standards.

NATURE OF POTENTIAL CONFLICT:

[Describe the type: Financial interest / Family relationship / Outside employment / Board service / Personal relationship / Business opportunity / Other]

DETAILED DESCRIPTION:

[Provide comprehensive details about the situation:]

- What is the relationship or interest that creates the potential conflict?

- Who are the parties involved (individuals, companies, organizations)?

- When did this situation arise or when will it begin?

- How might this affect my judgment, decision-making, or duties?

- What specific work responsibilities or projects might be impacted?

RELEVANT CIRCUMSTANCES:

[Explain any additional context that helps understand the situation fully]

CURRENT OR ANTICIPATED INVOLVEMENT:

[Describe your role, responsibilities, or decision-making authority in matters where the conflict exists]

PROPOSED MITIGATION MEASURES:

[Suggest how the conflict might be managed, such as:]

- Recusing myself from specific decisions or discussions

- Transferring certain responsibilities to colleagues

- Increasing oversight or review of my work in affected areas

- Limiting or ending the relationship creating the conflict

- Other approaches to minimize ethical concerns

I am committed to resolving this matter in a way that upholds organizational integrity and eliminates any appearance of impropriety. I am prepared to follow whatever guidance or directives you provide to address this situation appropriately.

I request a meeting to discuss this disclosure and determine the best path forward. Please let me know your availability and any additional information you need from me.

Thank you for your attention to this matter.

Respectfully,

[Your Name]

[Title]

[Department]

[Contact Information]

[Date]

[Signature]

Subject: Ethics and Code of Conduct Compliance Requirements for [Vendor/Contractor Name]

Dear [Vendor/Contractor Representative],

As part of our ongoing business relationship with [Your Company Name], we require all vendors, contractors, and third-party partners to acknowledge and comply with our Ethics and Code of Conduct standards. This ensures alignment with our organizational values and legal obligations.

APPLICABILITY:

This ethics compliance requirement applies to your organization and all individuals who will be providing services to or on behalf of [Your Company Name], including employees, subcontractors, and agents.

KEY ETHICAL STANDARDS YOU MUST UPHOLD:

- Integrity and Honesty: Conduct all business dealings truthfully and transparently

- Legal Compliance: Adhere to all applicable laws and regulations

- Confidentiality: Protect proprietary and sensitive information

- Conflict of Interest: Disclose any conflicts that may affect your objectivity

- Anti-Corruption: Refuse to engage in bribery, kickbacks, or improper payments

- Fair Dealing: Compete fairly and treat others with respect

- Reporting: Immediately report suspected violations or ethical concerns

PROHIBITED ACTIVITIES:

[List specific prohibited behaviors relevant to the vendor relationship]

REQUIRED ACTIONS:

1. Review the attached Ethics Policy Summary for Third Parties

2. Complete and return the signed Vendor Ethics Compliance Acknowledgment Form by [Date]

3. Ensure all personnel working on our projects receive this information

4. Report any ethics concerns to [Ethics Hotline/Contact Information]

REPORTING MECHANISMS:

If you become aware of any ethical violations or have questions about ethical standards, please contact:

- Ethics Hotline: [Phone Number]

- Email: [Ethics Email Address]

- Online Portal: [Website]

CONSEQUENCES OF NON-COMPLIANCE:

Failure to comply with these ethical standards may result in contract termination, legal action, and exclusion from future business opportunities with our organization.

We value our partnership and trust that you share our commitment to the highest ethical standards. If you have questions about these requirements or need clarification on any provision, please contact our Procurement or Compliance department.

Thank you for your cooperation and commitment to ethical business practices.

Sincerely,

[Your Name]

[Title]

[Company Name]

[Contact Information]

[Date]

Attachments:

- Ethics Policy Summary for Third Parties

- Vendor Ethics Compliance Acknowledgment Form

Subject: Confirmation of Whistleblower Protection Following Your Report

Dear [Employee Name],

Thank you for coming forward to report your concerns regarding [general description without revealing confidential details]. Your willingness to speak up demonstrates your commitment to our organizational values and helps us maintain the highest ethical standards.

PROTECTION UNDER POLICY:

This message confirms that you are protected under our Ethics and Code of Conduct Policy and applicable whistleblower protection laws. Our organization strictly prohibits retaliation against anyone who reports suspected violations in good faith.

YOUR RIGHTS INCLUDE:

- Protection from termination, demotion, or disciplinary action due to your report

- Protection from harassment, intimidation, or hostile treatment

- Confidentiality to the extent possible under investigation requirements

- Right to report any retaliatory behavior immediately

- Continued employment under the same terms and conditions

WHAT HAPPENS NEXT:

- Your report has been assigned to [investigator/department] for review

- Investigation will be conducted promptly and thoroughly

- You may be contacted for additional information or clarification

- Updates will be provided as appropriate while maintaining investigation integrity

- Outcome will be communicated in accordance with policy and privacy requirements

IF YOU EXPERIENCE RETALIATION:

Should you experience any form of retaliation or adverse treatment that you believe is connected to your report, please immediately contact:

- Human Resources Director: [Name, Contact]

- Ethics Hotline: [Phone Number]

- Legal/Compliance Department: [Contact]

CONFIDENTIALITY REMINDER:

We ask that you maintain confidentiality about your report and the investigation to preserve the integrity of the process and protect all parties involved.

We appreciate your integrity and courage in reporting this matter. Your actions help us maintain a workplace culture where ethical behavior is expected and protected.

If you have any questions or concerns about your protections or the investigation process, please don't hesitate to contact me directly.

Sincerely,

[Ethics Officer/HR Director Name]

[Title]

[Contact Information]

[Date]

Subject: Quick Reminder: Our Commitment to Ethics (Action Required)

Hi Team,

It's that time of year again – our annual ethics policy review and acknowledgment. I know policy reminders aren't the most exciting emails in your inbox, but staying aligned on our ethical standards is crucial to who we are as an organization.

WHY THIS MATTERS:

Ethics isn't just about avoiding big scandals – it's about the daily choices we make, how we treat each other, and the integrity we bring to our work. Your commitment to these standards makes our workplace better for everyone.

WHAT YOU NEED TO DO:

✓ Review the Ethics and Code of Conduct Policy (link below – takes about 15 minutes)

✓ Complete the brief online acknowledgment form by [Deadline Date]

✓ Ask questions if anything is unclear – seriously, we'd rather answer questions than have confusion

QUICK REFRESHER ON KEY POINTS:

- Treat everyone with respect (always non-negotiable)

- Protect confidential information (yes, even after happy hour)

- Disclose conflicts of interest (better to ask than assume it's fine)

- Speak up if something doesn't seem right (we've got your back)

- Use company resources appropriately (your manager's probably not thrilled about personal printing projects)

NEED TO REPORT A CONCERN?

Ethics Hotline: [Phone Number] (available 24/7, anonymous if you prefer)

Email: [Ethics Email]

Talk to your manager, HR, or any leader you trust

No question is too small, and no concern is too minor. When in doubt, just ask.

Thanks for taking ethics seriously and helping us maintain the kind of workplace we're all proud to be part of. Let me know if you need anything.

[Name]

[Title]

[Date]

P.S. – If you've already completed your acknowledgment, thank you! You can ignore this reminder and enjoy one less thing on your to-do list.