CODE OF ETHICS AND GOOD CORPORATE GOVERNANCE
ETHICAL COMMITMENTS WITH STAKEHOLDERS
It is necessary to be clear about the stakeholders and the relationship established with Clínica Colombia ES in order to define the commitments and agreements that guarantee the quality of the service provided and the final satisfaction of the external client.

Towards the users

• Provide timely services with quality, warmth, clean and pleasant physical infrastructure, friendly, qualified, responsible and capable personnel.
• Provide spaces for dialogue for the community (auditoriums, mailboxes, etc.).
• Provide spaces for collaboration with the institution.
• Allow participation in decision making through committees and user associations.

Towards the internal customer (employees)

• Provide friendly and fair treatment.
• Promote spaces for dialogue and socialization of information of interest for the exercise of functions.
• Fulfill duties in full (timely payment, vacation scheduling, etc.) Provide ongoing training to staff.

To external entities

• Delivering information in a transparent and timely manner.
• Fulfill obligations and commitments in a truthful and timely manner.
• Impartiality in the treatment of contractors.
• Honest contracting in accordance with the legal framework.
• Ensure the best quality of the contracted services or products.
• Support suppliers in the improvement of their processes.

Towards the environment

• Responsible consumption of resources (water, energy, telephone).
• Recycling of reusable items (paper, glass, cardboard, etc.).
• Use of appropriate containers for waste classification.
• Follow-up of the deposit of hazardous elements, waste route, final disposal.

CONFLICT OF INTEREST

A conflict of interest is understood as a situation in which an employee has or assumes commitments that respond to external interests or obligations or with third parties, which jeopardize his or her dedication and honorability, and casts doubt on the ethical nature of his or her behavior.

SITUATIONS THAT MAY GIVE RISE TO CONFLICTS OF INTEREST

The clinic relies on the commitment, transparency, good judgment and good faith of its collaborators, as an essential element for the management of their personal and professional affairs and for the handling of situations involving conflicts of interest. In any case and by way of example only, the following situations are identified as generating conflict of interest:

• Make any personal investment in a company, if such investment could affect or appear to affect his or her ability to make impartial and objective decisions regarding business related to the Clinic.
• Conduct or participate in businesses in which the counterparty is the Clinic and in which the employee has a personal or family interest. Likewise, participation in companies that have established or seek to establish business with the Clinic.
• Participate in the acquisition, contracting or investment decisions of assets for the clinic, when the employee, his/her spouse or relatives or companies in which they have a share in the capital stock, are the suppliers of the respective asset.
• The Clinic’s employees may not receive money or commissions on a personal basis, as this activity may promote a biased decision.
• According to the Clinic’s guidelines, it is allowed to make or accept normal social attentions within the normal activity of internal and external relations and that have a defined Institutional objective.

CONFLICT RESOLUTION

When an employee is faced with a situation in which two opposing interests are present, the following considerations should be taken into account:

•  The employee must disclose to his or her immediate superior the nature and extent of any conflict between his or her own interests and those of the clients.
• If a situation arises that could be considered a conflict of interest in a negotiation with persons or entities related to those who do business on behalf of the Clínica, either by affinity or consanguinity, the employee must inform his or her immediate superior and the negotiation must be carried out by a person other than the person who presents the conflict of interest.
• Avoid attending to personal matters during working hours or making use of the organization’s resources.

The clinic considers that conflicts of interest must be managed and resolved according to the particular characteristics of each case. Any situation that raises doubts regarding the possible existence of a conflict of interest must be dealt with as if it existed.
All managers and collaborators who are faced with a possible conflict of interest or consider that they may be faced with one, must immediately inform their hierarchical superior of the situation, who in turn will inform the next level up to one of the members of the Steering Committee, who will inform the Steering Committee at its next meeting, or earlier if the situation warrants it.

SUPPLIER MANAGEMENT

Suppliers are selected through an evaluation process that contains the following conditions:
Invima registration, Chamber of Commerce, registration evidencing certification in Good Manufacturing Practices and cost evaluation in their products, and SARLAFT form. Three quotations will always be taken into account to define the supplier, except for those medicines and/or supplies that are scarce in the market and have a single supplier.
For the purchase of a new medical device or medication, the consent of the pharmacy committee is required to ensure patient safety. The acquisition of highly complex medical equipment, due to technological updating, replacement or the opening of new services, must be channeled through the Medical Director, who in association with the Purchasing Committee, will study the alternative that best suits the Clinic’s needs, taking into account economic aspects, experience of the supplier, brand of equipment, technological development, installation, training and guarantee.

IMPLEMENTATION STRATEGIES

The clinic is committed to disseminate this Code among all employees and periodically evaluate their knowledge of it. To this end, it has established that the Strategic Prospective Committee will be responsible for ensuring the updating, dissemination, compliance and monitoring of the provisions noted in this code. Dissemination will be carried out with the following strategies:

• Publish the document in the document platform of the quality management system for the knowledge and consultation of all personnel.
• It must be presented in the Institutional Induction and Reinduction.
• Conduct training sessions in the virtual classroom.
• Web page and intranet.
• Institutional video

CONTROL AND FOLLOW-UP

In order to control and monitor compliance and improvement of processes and procedures, execution of activities and compliance with regulations, Colombia Clinic uses the following forms of control:
Internal Audits: established within the Audit Plan of the Evaluation and Improvement Process (Internal Control and Quality), for the Improvement of Quality PAMEC.
Fiscal Auditing: Its general objective is to exercise a timely, comprehensive and permanent control over the acts of the administrators, corporate operations, assets, rights, books, vouchers, correspondence and other inherent documents, in order to ensure the timely, efficient, effective and transparent management of resources and thus achieve the adequate provision of essential health services to the population residing in the Colombian territory.