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Ramsay Health Care Limited Annual Report 2016

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 companies over which they have 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 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). Global Anti-Bribery & Corruption Policy 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 has in place a Global Anti-Bribery and Corruption Policy. This 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 and was rolled out across each business unit throughout FY2016. The Policy also sets out the Company’s expectations of its third party suppliers, and includes a requirement for the Company’s employees to take steps to satisfy themselves that the Company is dealing with suppliers that do not engage in bribery/corruption. The Board, through the Global RMC, has primary responsibility for ensuring that the Global Anti-Bribery and Corruption Policy is complied. The Global RMC has further delegated responsibility to test compliance with our Global Anti Bribery & Corruption Policy to the General Manager – Audit & Risk, who reports to the Global RMC on a quarterly basis. During FY2016, the Global RMC requested the General Manager – Audit & Risk to engage Deloitte to assist the Company in devising a programme to test the Company’s internal controls on preventing (and detecting) bribery and corruption in the Company’s business. It is expected that this programme will be finalised and rolled-out throughout the business in FY2017. Global Human Rights & Labour Policy (Modern Slavery Act Statement) During FY2016, the Board established the Ramsay Human Rights & Labour Policy. The Policy, which applies to all of the Company’s businesses worldwide, sets out (among other things) the Company’s commitment to only engage workers who have capacity, are of legal age and have a free will and consent to work. This Global Policy also sets out the steps that must be taken by the Company’s business units to uphold this commitment. Each year, the Modern Slavery Act 2015 requires the Company to prepare a Statement on the steps it has taken to mitigate the risk of slavery or human trafficking in its business or supply chain. The Company’s FY2016 Modern Slavery Act Statement can be viewed via a link on the Company’s homepage, www.ramsayhealth.com, under the ‘Sustainability’ tab. Other Policies The Company also has in place a Code of Conduct for Agents, Manufacturers and Suppliers with whom the Company does business, which has been distributed internally and progressively implemented as a term of key supplier contracts as those contracts are entered, reviewed or renewed. Copies of the Company’s Whistleblower Policy, Global Anti Bribery and Corruption Policy, Human Rights & Labour Policy and Code of Conduct for Agents, Manufacturers and Suppliers are available in the Sustainability section of the Company’s website (www.ramsayhealth.com/Sustainability/Social/Workforce%20Standards). ANNUAL REPORT 2016 25


Ramsay Health Care Limited Annual Report 2016
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