One of the key changes that was made in the new the Securities Trading Policy is that the Company has adopted “trading blackouts”, rather
than trading windows, for “Restricted Employees” to trade. Under the “trading blackouts”, “Restricted Employees” (including Directors,
officers and senior executives) and their families and trusts or companies over which they have influence or control are prohibited from
trading directly or indirectly in Company securities during the two blackout periods, being:
• the period from the close of trading on the ASX on 30 June each year, or if that date is not a trading day, the last trading day before that
day, until the day following the announcement to ASX of the full-year results;
• the period from the close of trading on the ASX on 31 December each year, or if that date is not a trading day, the last trading day before
that day, until the day following the announcement to ASX of the half-year results; and
• any other period that the Board specifies from time to time.
The only exception to this prohibition is where the Restricted 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.
Restricted Employees are permitted to trade at any time other than during the “trading blackout” periods 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
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, which
was reviewed and updated during FY2017. 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 FY2017. 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/
During FY2017, the Board adopted a Global Gifts & Hospitality Policy. This Policy supplements the Global Anti-Bribery & Corruption Policy’s
guidance on accepting and offering Gifts and Hospitality by establishing:
• monetary thresholds for Gifts and Hospitality that, if exceeded, must be approved before a Gift or Hospitality may be accepted; and
• protocols in relation to the giving of Gifts and/or Hospitality by or on behalf of Ramsay.
The Board, through the Global RMC, has primary responsibility for ensuring that both the Global Anti-Bribery and Corruption Policy and
Global Gifts & Hospitality Policy is complied with. 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. A formal programme
to assist the Company in testing the Company’s internal controls on preventing (and detecting) bribery and corruption in the Company’s
business is currently being designed.
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 (UK) 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 FY2017 Modern Slavery Act Statement can be viewed via a link
on the Company’s homepage, www.ramsayhealth.com, under the ‘Sustainability’ tab.
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
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.
Central to The Ramsay Way and the Company’s desire to retain its status as one of the world’s most sustainable organisations is its
commitment to the environment. The Company has in place an Environmental Sustainability Policy, setting out the principles underpinning
the Company’s commitment towards environmental sustainability which are intended to form part of, and to support, all Ramsay activities.
The Company’s Environmental Management System (EMS) aims to implement the Policy and procedures developed under it, and to establish
individual roles, a reporting structure and a programme for monitoring and auditing performance.
The Company has been included in the FTSE4Good Global Index every year since 2011. The FTSE4Good Global Index is a global index
identifying companies that demonstrate strong environmental, social and governance practices (ESG), measured against globally recognised
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