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Anti-corruption Policy

At Dar El Oyoun Hospitals & Centers "DEO" the way we do things is just as important as what we do.


Of course, we want to be the best in our healthcare industry… but not by any mean and not at any price. We want to create an environment where each employee starting from the Chief Operating Officer to achieve the highest business and personal business standards, and where everyone feels proud of our chain of centers and hospitals and the job which he or she are doing.

DEO is a team with core values: accountable, responsibility, honesty, patient focused, socially responsible and team driven.

These values guide how we work every day. We bring these values to life in the way we perform, giving our best effort every day, being accountable for what we do, delivering on our commitments to each other and to our customers, setting objectives, meeting our goals, and working together to achieve business results. A core objective of our Company is creating a winning and inclusive culture that drives results. As laid out in our Code of Business Conduct (DEO-COBC) you are expected to adopt the "RIGHT WAY", the highest standards of professional and personal behavior and demonstrate respect, integrity, good judgment, honesty and trust in all your actions, no matter what the circumstances. The main guiding principles of the DEO-COBC are ‘complying with anti-corruptions policy’. The Anti-Corruption Policy extends on this principle, and is applicable to all employees and everyone we do business with, including agents, representatives, consultants, independent contractors and anyone acting on behalf of DEO. If you have any questions regarding DEO’s Anti-corruption policy, please contact our Ethics and Compliance Officer Mr.Omar Bekheit and, or, our local Legal Officer Mr.Hamza Hassan.Introducing corruption can cause distortion in markets and harms economic, social and political developments, particularly in a developing country like Egypt.

Bribery is a common form of corruption, and includes any gift, payment or other benefit to which the recipient is not legally entitled and which is offered in order to secure an improper business or other advantage.

Purpose of the Anti-Corruption Policy:

The purpose of this Policy is to describe DEO's core principles on corruption and bribery and to provide to all DEO's Family detailed processes, policies and procedures to implement and have in place in order to uphold, adopt and apply these core principles.

This policy outlines a DEO's behaviors to ensure compliance with anti-corruption Initiative.

This includes compliance with all laws, domestic and foreign, prohibiting improper payments, gifts or inducements of any kind to and received from any person, including officials in the private or public sector, customers and suppliers.

Helpful Definitions:

Bribery:

Anything of value, given in an attempt to affect a person’s actions, or decisions, in order to gain or retain a business advantage.

Anything of value includes cash, entertainment or other gifts or courtesies.

A bribe is an inducement or reward received, offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

Corruption:

The misuse of a public office or power for private gain, or the misuse of private power in relation to business outside the realm of government.

Facilitation payments:

Small sums paid to government officials to facilitate or expedite routing.

Non-discretionary government actions are considered facilitation payment.

Kickbacks:

The return of a sum already paid, or due, as a reward for awarding of furthering business.

A conflict of interest would arise if:

-       Any employee placed a contract on behalf of a group company with a supplier who was managed by a close friend or family member or  worked as a consultant in a private capacity for a supplier or customer of a group company.

-       Carried on a business in their own time of a similar nature to their own work in the group

-       Had a personal or financial interest in any business that has transactions or dealings with a group company where the employee can influence decisions by the group company about the dealings with that business.

-       Obtained a personal financial gain or advantage (other than normal remuneration) in business transactions or dealings involving any group company.

-       No executive shareholder or employee must use inside information gained through employment with a group company for his/her own advantage or for that of a friend or relative or any other person.

-       No executive shareholder or employee must personally exploit a corporate opportunity such as the purchase of property or investment in an enterprise in which any group company has an existing interest of any kind whatsoever, or in which the employee has reason to believe that any group company may have a prospective interest.

What Does 'Anti-Corruption' mean to you?

Corruption can take place in many types of activities. It is usually designed to obtain financial benefits or other personal gain.  

For example, bribes are intended to influence behavior – they could be in the form of money, a privilege, an object of value, an advantage, or merely a promise to influence a person in an official or public capacity.

Usually, two people are involved and both will benefit.  

Examples of a bribe include:

- Offer or receipt of cash in the form of a kickback, loan, fee or reward

- Giving of aid, donations or voting designed to exert improper influence

In Our business environment, the areas of business where corruption, including bribery, can most often occur include:

A. Procurement Process

B. Licensing Process

C. Facilitation Payments

D. Gifts, Entertainment and Hospitality

E. Political, Community and Charitable Contributions

A.    Procurement Process Equality & Transparency and internet announcement for all tenders is our culture.

You must follow DEO processes and adhere to the system of internal controls around supplier selection.

Supplier selection should never be based on receipt of a gift, hospitality or payment. When supplier selection is a formal, structured invitation for the supply of products or services (often called a ‘tender’), it is most important we maintain documentation supporting our internal controls.

In the public sector, such a tender process may be required and determined in detail by law to ensure that such competition for the use of public money is open, fair and free from corruption.

A tender process includes an invitation for other parties to make a proposal, on the understanding that any competition for the relevant contract must be conducted in response to the tender, no parties having the unfair advantage of separate, prior, closed-door negotiations for the contract where a bidding process is open to all qualified bidders and where the sealed bids are in the open for scrutiny and are chosen on the basis of price and quality.

B.    Licensing Process:

 You must follow DEO processes and adhere to the system of announced government controls for license.

Breaching the law should never be done intently by any of DEO's family. Everyone should be proud that DEO's policy is Do Not Breach the Law.

C.    Facilitation Payments:

Facilitation payments are not allowed. If you are unsure whether certain payments represent facilitation payments, please contact your local Legal Officer, or the Ethics and Compliance Office.

D.    Gifts Gifts and other similar issues:

If they are reasonable, proportionate and made in good faith and in compliance with our company policies, these activities must be in compliance with our Code of Business Conduct (guiding principle: ‘avoiding conflicts of interest’), DEO’s Customer Entertainment Policy and Corporate Hospitality Guidelines. Although no two situations are the same, the Corporate Hospitality Guidelines define what is usually a DEO Acceptable and what is never a DEO acceptable.

Examples of gifts, entertainment and hospitality include the receipt or offer of gifts, meals or tokens of appreciation and gratitude, invitations to events, functions, or other social gatherings, in connection with matters related to our business.

These activities are a DEO acceptable provided they fall within reasonable bounds of value and occurrence.

How do you know if an offered gift, entertainment or hospitality by DEO or to DEO is a DEO acceptable? First, take a step back and ask yourself the following:

• What is the intent – is it to build a relationship or is it something else?

• How would it look if these details were on the front of a newspaper?

• What if the situation were reversed – would there be a double standard?

If you find it difficult to provide a comfortable answer to one of the above questions, ASK your manager, local Legal Department or the Ethics and Compliance Office.

What to do when you doubt if you can a DEO acceptable?

If you are unsure if you should a DEO acceptable something of value – ASK.

Ask your manager. If your manager is participating, seek a higher-level manager. If you prefer, ask your local Legal Department or contact the Ethics and Compliance Office.

As a general rule, DEO employees and business partners should not provide gifts or hospitality to, or receive them from, a government or other public official (or their close families and business associates).

You may give a modest gift to these parties when appropriate and allowed by local law provided you discussed it with and received written approval in advance from the legal department.

Please refer to our Code of Business Conduct, “Engaging in Government and Political Activities” which allows political contributions as permitted by law and only when approved in advance by our senior public affairs officer and legal counsel.

E.    Political Community and Charitable Contributions:

You are not allowed to make political contributions from company funds without authorization.

Political contributions, as permitted by law, must be approved in advance by our senior public affairs officer and legal counsel.

Importantly, DEO's Policy stated that political contributions in any country is not permitted.Contributions made by DEO to community projects or charities need to be made in good faith and in compliance with our Code of Business Conduct, this Anti-Corruption Policy and all relevant DEO ’s policies and procedures. Books, Records and Internal control requirements:  it is your responsibility to be knowledgeable of control procedures and ensure compliance.

International anti-corruption laws generally require detailed and accurate accounting records for transactions, including cash and bank accounts.

We must ensure we maintain accurate books, records and financial reporting.

All business departments & units and branches must maintain an effective system of internal control and monitoring of our transactions.

Certain monitoring controls are identified in our policies, specifically regarding approval of travel for scientific conferences and entertainment expenses.

You are the one Responsible; we do not accept "I did not know" as an answer".

DEO takes corruption and bribery very seriously.

Any violation of this policy will be regarded as a serious matter by the Company and is likely to result in disciplinary action, including termination, consistent with local law.

Bribery is a criminal offense. As an employee you will be accountable whether you pay a bribe yourself or whether you authorize, assist, or conspire with someone else to violate an anti-corruption or anti-bribery law.

Punishment for violating the law are against you as an individual and may include imprisonment, probation, mandated community service and significant monetary fines which will not be paid by DEO .

Receipts of gifts and hospitality must be acknowledged on the relevant headed paper of the Business or by email within seven days.

Raise a Concern and protect your company if you want to ask a question about the requirements in this policy or are concerned that an anti-corruption violation is occurring or has occurred.

Report it immediately to one of the following:

• Your manager

• Ethics and Compliance Office, directly by contacting Mr.Omar Bekheit DOE's Chief Internal Audit and Risk Officer

• Your local Legal department officer Mr.Hamza Hasan

ANTI CORRUPTION AND BRIBERY EFFECTIVE DATE: 29 March 2014 Policy Ownership This Policy is owned by DEO’s legal department. 

Please contact your local legal department or the Ethics & Compliance Office for any questions, or send an email to: ethics@dareloyoun.org

The policies on this site apply to all employees of DEO Hospitals & Centers and DEO Hospitals & Centers subsidiaries unless otherwise specified or as required by National, Country, Province or Local law.  


Dr. Khaled Samir, CEO  


Khaled.ceo@dareloyoun.org



19th March 2014



 


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