INTEGRITY & ANTI BRIBERY

 1. OUR VISION 

To be the preferred healthcare facilities management company in the region.

 2. MISSION 

Excellent service delivery via integration of competent workforce and collaborative approach with all stakeholders.

 3. INTRODUCTION 

Integrity and fairness are central to how we operate both in the workplace and the marketplace. To achieve our mission, we consider it business-critical to work with suppliers who share our commitment to integrity and who support an ethical and compliant culture.

We hold our suppliers to the same high standards of business conduct and social and environmental responsibility. One Medicare complies with all local workplace regulations and is committed to treating all stakeholders with respect and dignity.

We expect our suppliers to:

• Comply with local regulations;

• Uphold human rights;

• Ensure a safe and healthy workplace;

• Demonstrate social and environmental responsibility; and

• Conduct business in an ethical manner.

 4. PURPOSE 

This Supplier Code of Conduct has been developed to incorporate the principles of the One Medicare Anti-Bribery and Corruption SOP, which details the ethical framework for how we manage our business and governs the work we do each day. The same fundamental elements outlined in Anti-Bribery and Corruption SOP are expected to be supported and promoted by our suppliers, contractors, consultants, and business partners. We will not knowingly do business with suppliers who violate these expectations.

One Medicare suppliers are expected to understand and comply with the One Medicare Supplier Code of Conduct and One Medicare reserves the right to verify the supplier’s compliance with it at any time.

 5. SCOPE 

This Policy is applicable to all Suppliers, Contractors and Consultants of One Medicare Sdn. Bhd.

 6. RESPONSIBILITY AND AUTHORITY 

The responsibility to review, amend, update, obtain approval to implement or delete this One Medicare Supplier Code of Conduct lies with the Senior Manager, Corporate Services of One Medicare Sdn. Bhd. (originator of this procedure).

 7. GOVERNANCE & ETHICS 

7.1 Ethics and Legal Compliance:

One Medicare is committed to conducting its business in compliance with all applicable laws and regulations, and with the highest ethical standards.

• One Medicare bases its supplier relationships on lawful and fair practices.

• Suppliers shall conduct their business competitively, with integrity and ethics.

• Suppliers must follow applicable laws, regulations, legal requirements, other contractual obligations and uphold the fundamental elements of human rights.

• Suppliers are responsible for ensuring that they and their employees, independent contractors, representatives, subcontractors comply with the standards of behavior in this document.

7.2 Anti-Corruption and Anti-Bribery:

One Medicare forbids bribery and corruption in the conduct of its business. It is One Medicare’s Anti-Bribery and Anti-Corruption Policy to comply with all applicable anti-bribery and anti-corruption laws. This includes laws that prohibit bribery of government officials and employees.

• Suppliers are required to comply with anti-corruption and anti-bribery laws of every country in which they conduct business.

• Suppliers are prohibited from offering, requesting, agreeing to receive, or accepting a bribe, kickback, payment for advertising, gifts disguised as allowances or expenses, or any other improper financial or other advantage to government officials, health care professionals, or anyone else. This includes anything of value, including cash, gifts, entertainment, offers of employment, or participation in a contest game or promotion to any One Medicare employee, representative, customer or to any government official.

• Facilitation payments, regardless of whether permitted by local law, are also prohibited.

• Suppliers are prohibited from activities that directly or indirectly offer, promise, pay, give, or authorize the giving of any financial or other advantage, or anything of value, to any other person or organization, in order to exert improper influence over the recipient, induce the recipient to violate his or her duties, secure an improper advantage for the Company, or improperly reward the recipient for past conduct.

• Suppliers will maintain and enforce a policy requiring adherence to lawful business practices, including a prohibition against bribery and extortion of government officials.

• Suppliers are required to maintain books and records that accurately and fairly reflect transactions in reasonable detail and that internal controls are maintained to prevent and detect potential violations of policy or applicable law. No false or misleading entries may be made in the books and records for any reason, and all payments and transactions, regardless of value, must be recorded accurately.

Compliance Reporting: One Medicare is committed to the highest possible standards of ethical, moral and legal business conduct. To help facilitate the reporting of good faith concerns regarding, among other things, Legal and Ethical Issues, Accounting and Finance, Discriminatory Employment Practices, Harassment and/or Misconduct, Substance Abuse concerns, Breach of Confidentiality, Environmental Health & Safety Issues, Anti-Bribery and Regulatory violations, One Medicare has established an Integrity Unit under the Corporate Services Department.

7.3 Human Rights:

One Medicare is committed to respecting human rights and to treating every stakeholder with respect. We expect One Medicare suppliers to similarly treat all stakeholders with respect and dignity.

• Suppliers shall ensure respect for human rights in throughout their operations (including but not limited to the operations of their own suppliers and any permitted sub-contractors).

• Suppliers shall respect human rights of their employees and others in their business operations and with their activities with One Medicare.

7.4 Competition Law:

• Suppliers shall never share or exchange any price, cost or other competitive information or engage in any collusive conduct with any third party with respect to any proposed, pending or current One Medicare services/products and or procurement.

7.5 Security and Privacy:

• Suppliers are expected to protect One Medicare confidential and proprietary information. Any information or data regarding One Medicare operations shall always be treated as strictly confidential unless that information is in the public domain.

• Suppliers shall respect privacy rights and secure the data of One Medicare employees, customers, and suppliers (collectively, “One Medicare Data”).

• Suppliers shall implement and maintain physical, organizational and technical measures to ensure the security and confidentiality of One Medicare Data to prevent accidental, unauthorized or unlawful destruction, alteration, modification or loss of One Medicare Data, misuse of One Medicare Data, or unlawful processing of One Medicare Data.

• Suppliers shall comply with applicable security and privacy laws and regulations as well as data retention requirements in all situations when conducting business with One Medicare.

• Suppliers must ensure that, at all times, they have appropriate technical and security measures in place to protect One Medicare’s confidential information from unauthorized disclosure. Suppliers may not outsource, disclose, share, or use this information with anyone, or for any purpose, outside the terms of their agreement(s) with One Medicare.

• The One Medicare logo must not be used without written approval.

7.6 Intellectual Property:

• Suppliers shall honor the intellectual and other property rights of One Medicare and of third parties, including all patents, trade secrets, trademarks and copyrights.

• Any use, disclosure and handling of One Medicare intellectual property must be in accordance with any applicable agreements.

7.7 Trade Controls and Customs Matters:

Suppliers will not transfer One Medicare technical information to any third party without the prior express, written consent of One Medicare, and will comply with all applicable trade control laws and regulations in the import, export, re-export or transfer of goods, services, software, technology or technical data including any restrictions on access or use by unauthorized persons or entities.

7.8 Controllership:

Suppliers will ensure that all invoices and any customs or similar documentation submitted to One Medicare or governmental authorities or audited by third parties about transactions involving One Medicare accurately describe the goods and services provided or delivered and the price thereof and ensure that all documents, communications and accounting are accurate and honest.

7.9 Supplier Diversity:

One Medicare is committed to diversity, inclusion, and fairness in all we do. Our commitment extends beyond our workforce and into our supply chain and communities.

 8. PEOPLE 

One Medicare suppliers are expected to treat their employees with respect and dignity. One Medicare supports the elimination of discriminatory practices with respect to employment. We are committed to fair and respectful treatment. We are committed to and promote equal opportunity and diversity in the workplace and in all aspects of our business operation. We expect our suppliers to provide employment and advancement opportunities to individuals based on merit and not tolerate acts of discrimination.

• Suppliers shall comply with all applicable labor laws, rules, and regulations, including but not limited to, Employment Act 1955 and Sarawak Labour Ordinance 1952 and Industrial Relations Act 1967 (2010 revision).

• Suppliers will observe applicable laws and regulations governing wages and hours and employment contracts recruitment. 

• Suppliers will prohibit discrimination, harassment, retaliation, and discrimination.

• Suppliers will provide fair and respectful treatment and equal opportunity. They will provide fair wages, benefits, and working hour schedules that comply with applicable laws and collective agreements.

• Suppliers must practice ethical recruitment. They must provide written documents with terms and conditions of employment in a language the candidate can understand and ensure third party recruitment agencies are compliance with provisions of the law and this policy.

 9. ENVIRONMENT, HEALTH, SAFETY & SUSTAINABILITY 

9.1 Health and Safety:

One Medicare is committed to a safe and healthy work environment for all our employees, contractors and the communities where we operate. We expect our suppliers to provide a safe and healthy work environment.

• Suppliers will comply with applicable health and safety laws and regulations.

• Suppliers will provide a safe and healthy working environment.

• Suppliers will provide a work environment free from violence and harassment of any kind that threatens, intimidates, or coerces another person.

• Suppliers shall make available safety information related to hazardous materials in the workplace and train employees on protection from hazards.

• Suppliers shall implement emergency response plans and procedures.

9.2 Environment:

As a global corporate citizen, One Medicare recognizes the importance of the environment to a healthy, sustainable future for our business, our patients, and communities. We are committed to safeguarding earth’s resources and to continuously strengthening our environmental stewardship through our facilities, our products, and supply chain.

• Suppliers will comply with applicable environmental laws and regulations.

• Suppliers shall operate in an environmentally responsible and efficient way to minimize impact on the environment.

 10. Sustainability 

• Suppliers are expected to commit to establishing and monitoring goals associated with the reduction of their environmental footprint.

•  Suppliers should conserve natural resources by reducing energy, water, and waste.