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2015 Ramsay Health Care Limited Annual Report

14 Ethical and Responsible Behaviour Code of Conduct and Whistleblower Policy The Company places the highest value on ethical and responsible behaviour and has established a Code of Conduct for all Directors, officers and employees as to: • the practices necessary to maintain confidence in the Company’s integrity; • their legal obligations from time to time and the reasonable expectations of the shareholders; and • the responsibility and accountability of individuals for reporting and investigating reports of unethical practices. The Code of Conduct, which is available in the Sustainability section of the Company’s website (www.ramsayhealth.com/sustainability/ social/workforce%20standards), is the subject of periodic review to ensure that it covers all relevant issues and sets standards consistent with the Company’s commitment to ethical and responsible behaviours. Employees are encouraged to report any concerns regarding serious misbehaviour including theft, fraud, bribery, breach of policies, dishonesty, harassment, bullying, unlawful discrimination, unethical or negligent behaviour, workplace safety hazards and medical negligence through the Ramsay Whistleblower Programme. The programme has been implemented in all Ramsay facilities in Australia and the UK and includes an independent hotline service operated by Deloitte to encourage anonymous disclosures by providing a mechanism by which employees may confidentially register complaints with an organisation independent of the Company and which will in turn refer complaints to senior managers of the Company for investigation. All reports are monitored by the Whistleblower Committee, which reports to the Audit Committee. In relation to the Company’s Asian joint venture, a new formal whistleblowing policy was implemented in March 2015. The Company’s whistleblowing arrangements in France are currently being reviewed. Securities Trading Policy In line with ASX Listing Rule 12.9, the Company has in place a Securities Trading Policy. The Securities Trading Policy was reviewed in light of amendments to ASX Guidance Note 27 and the updated Securities Trading Policy was approved by the Board on 28 April 2015. Under the Securities Trading Policy, all employees are prohibited from dealing (or causing or encouraging a third party to deal) in Company securities at any time while they are in possession of price-sensitive information and from dealing in securities of other listed companies where they obtain price-sensitive information in relation to that other company in the course of their employment. In addition, the Securities Trading Policy prohibits certain “Nominated Employees” (including Directors, officers and senior executives) and their families and trusts or compaines over which they influence or control from trading directly or indirectly in Company securities outside of designated trading windows, being: • the two 6 week periods commencing on the next trading day after the release of full and half year results; • the 2 week period commencing on the next trading day after the Company’s Annual General Meeting; and • any other period the Board determines. The only exception to this prohibition is where the Nominated Employee has “exceptional circumstances” and has obtained written approval from the Chairman (or his delegate) and the Company Secretary to deal in Company securities outside the windows in accordance with the process set out in the Securities Trading Policy. Nominated Employees are permitted to trade in the trading windows set out above, subject to receiving clearance to deal in accordance with the process set out in the Securities Trading Policy. A copy of the Company’s Securities Trading Policy is available in the Corporate Governance section of the Company’s website (www.ramsayhealth.com/investors/corporategovernance). Other policies To supplement the prohibition on bribery, or acceptance by staff of gifts that are beyond general commercial practice or common courtesy under the Code of Conduct and the Whistleblower Policy, the Company adopted a Global Anti Bribery and Corruption Policy during FY2015. The new Global Policy, which builds on and consolidates the Company’s previous anti-bribery and corruption policies, now applies to all of the Company’s related bodies corporate worldwide. The Global Policy will be implemented across each business unit throughout FY2016. 26 RAMSAY HEALTH CARE ANNUAL REPORT 2015


2015 Ramsay Health Care Limited Annual Report
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