VideoKlinik Code of Conduct and Business Ethics
Introduction
Dijital Garaj Teknoloji Çözümleri Ltd. Şti (“VideoKlinik”) has adopted this Code of Conduct & Business Ethics (“Code”) regarding interactions with patients, healthcare professionals (“HCP”) and our business conduct within the industry generally. All interactions between VideoKlinik and patients and HCPs must be carried out in a responsible, ethical, professional and legal manner. This Code describes the fundamental principles and standards to which all individuals must adhere, including board members, officers, employees, contractors, and agents (referred to in this Code of Conduct as “Company Representatives”). This Code sets a minimum standard. Laws and industry guidance that set higher standards, or more specific conditions, take precedence over this Code. VideoKlinik will ensure that all Company Representatives are appropriately trained on the requirements of this Code. VideoKlinik also will develop, implement and maintain a Corporate Compliance Program and other written Compliance Program Policies and Procedures that are consistent with this Code. Any conduct that violates this Code is prohibited. Compliance with this Code and related policies is mandatory. Violations can have serious consequences for VideoKlinik and for Company Representatives. This Code incorporates principles set out in Conduct his/her responsibilities in compliance with this Code; Comply with VideoKlinik’s Corporate Compliance Program and any written policies, procedures and other guidelines; Protect VideoKlinik’s reputation by actively supporting ethical behavior; Promptly report any potential or actual non-compliance; and Fully and honestly cooperate in any investigation of alleged violation of this Code or VideoKlinik’s Compliance Program Policies and Procedures. VideoKlinik’s Corporate Compliance Program VideoKlinik is committed to conducting its business in compliance with the laws, regulations and other requirements that govern our operations. VideoKlinik provides resources to assist every individual within the Company, as well as our agents and vendors, to act in a legal and ethical manner. Reporting Potential Violations To encourage a workplace culture that keeps each Corporate Representative accountable to each other, VideoKlinik provides several methods for individuals to make reports in an anonymous manner. These include a Compliance Hotline and other forms of confidential communication. Our policy is to ensure the all good faith reports of misconduct or noncompliance are immediately investigated. VideoKlinik has a strict non-retaliation policy to protect VideoKlinik Representatives who raise concerns in good faith. No action of reprisal or retaliation will be taken against any VideoKlinik Representative for reporting a compliance concern or asking a question regarding our Compliance Program. Calls to the hotline or other types of reporting do not protect individuals from appropriate disciplinary action regarding their own performance or conduct.
Training and Education
The proper education and training of Company Representatives is a significant element of an effective compliance program. VideoKlinik is committed to the education of its Company Representatives on issues related to corporate compliance. As such, VideoKlinik has developed a training program that consists of compliance training to new hires and general training to all Company Representatives, and specific training sessions designed to target particular issues that only impact certain Company Representatives at VideoKlinik. Attention to training and compliance will be an integral part of the Company Representative evaluation process. Failure to comply with training and compliance requirements will result in disciplinary action, including possible termination. Healthcare laws and regulatory requirements VideoKlinik is committed to full compliance with all laws and regulations applicable to our business
Fraudulent Conduct is Prohibited
VideoKlinik does not tolerate fraud and is committed to the rigorous investigation of any suspected cases of fraud. Should any VideoKlinik Representative believe they have good reason to suspect a colleague or other individual is engaged in fraud or an offense involving VideoKlinik or a serious infringement of the Code, he or she should report such unethical action his or her or supervisor to the CCO. Privacy Requirements VideoKlinik respects the confidential nature of patient health information. Therefore, VideoKlinik must comply with all health information privacy and security laws. Generally, unless otherwise permitted or required by law, VideoKlinik will not disclose patient health information without prior authorization. VideoKlinik and its business partners will limit the collection of, and access to, personal data to circumstances that are consistent with clinical quality and other specific, legitimate business needs and applicable laws and regulations. All personal data must be treated as confidential unless otherwise required, secured against unauthorized access, and retained only for as long as it is necessary. VideoKlinik has adopted a number of additional Compliance Program Policies and Procedures addressing privacy issues that may affect its business activities.
Interactions with Healthcare professionals
Relationships with HCPs are heavily regulated and strictly enforced. An HCP is any individual or entity directly or indirectly involved in the delivery of health care services or items to patients and that can purchase, lease, prescribe, recommend, use or arrange for the purchase, lease or use of VideoKlinik’s products or services. VideoKlinik’s interactions with healthcare professionals, organizations and other authorities must be made in compliance with applicable laws, regulations, and VideoKlinik Compliance Policies and Procedures. Our general policy can be expressed in two main points: VideoKlinik or its Representatives may not condition a financial arrangement or provide free services or grants to HCPs in exchange for any agreement to purchase, order or recommend VideoKlinik products, or as a reward for high volume. Payments to HCPs will only be provided to HCPs in exchange for the provision of services for which there is a legitimate business need and a written agreement that provides for fair market value compensation.
