Business ethics and code of conduct, entertainments & gifts and conflict of interests
1. Purpose
- CMRC employees are required to maintain the highest ethical standards in the conduct of their affairs, both in a professional and personal capacity. The aim of this Handbook is to ensure that each employee conducts his or her affairs, and the business of CMRC, with the utmost integrity and complies with all applicable laws and regulations in a manner that excludes any consideration of personal advantage or gain. Given the close ties between CMRC and the Government of Abu Dhabi, the importance of adhering to the policies set out in this Handbook cannot be over-emphasized.
- This Policy shall apply, in its entirety, to all employees (including direct hires, temporary contractors, interns, trainees, volunteers, consultants, seconders, directors etc.).
- In all circumstances, employees should avoid putting themselves into a situation which may lead to breaching their ethical obligations; in situations of doubt as to whether any action or proposed action constitutes a violation of this Handbook, please consult your immediate manager or a member of CMRC HR Department.
2. CMRC Values
Each employee shall, throughout his tenure at CMRC, use his best endeavors to adhere to CMRC’s values (as set out below) in every aspect of his employment including, without limitation, time-keeping, appraisals, dealing with other employees and personal and work conduct. CMRC’s core values are:
- Adhere to the highest standards of professionalism, ethics and personal responsibility, worthy of the trust our patients place in us.
- Maintain the highest standards and achieve them by continually measuring and improving our outcomes.
- Provide the best care, treating patients and family members with dignity, sensitivity and empathy.
- Value the contributions of all, blending the skills of individual staff members in unsurpassed collaboration.
- Earn the trust and confidence of our patients, families and the communities we serve.
- Be inclusive; embrace and value different backgrounds, opinions, and experiences.
- Strive for excellence in all we do. Our focus is on continuous improvement, progress and achievement of individual and group goals.
3. Respect and Language
- One of the challenges of a multicultural workplace is the variety of languages and the choices we make in expressing ourselves. In CMRC we believe that all our staff wish to show respect to each other and will strive to maintain a high standard of personal conduct.
- In simple terms this means avoiding the use of any profane or potentially offensive language. If you are in any doubt about your choice of words then stop and find a different way to express yourself. Most of us do this automatically but it’s a good thing to occasionally reflect on our unconscious language habits.
- Displaying professionalism and showing respect for our colleagues also requires everyone to be aware of the content of their conversation topics – particularly in public areas. Be sure to avoid any conversations that other colleagues may judge to be inappropriate gossip, or having discussions that involve the sharing of potentially sensitive personal or CMRC data.
4. Entertainment and Gifts
Reasonable, necessary and proportionate entertainment and/or gifts may be given by CMRC employees to third parties, at CMRC’s expense, subject to senior management approval, provided that:
- The third party in question conducts significant and/or strategic business with CMRC;
- The entertainment or gifts are consistent with professional and ethical business practices. Unless there are exceptional reasons not to do so, entertainment and gifts should be sourced and agreed;
- The entertainment or gifts given are of sufficiently limited value and in a form that will not be construed as a bribe or pay-off;
- The entertainment or gifts given are not in violation of applicable laws; and
- Public disclosure of any fact or detail will not embarrass CMRC, its management or its employees.
5. Entertainment and Payments offered to CMRC Employees
Hospitality given and received is part of the general establishment of good business relationships. In the event you are offered hospitality (other than of a minor nature such as lunch), you should discuss this with your superior before accepting. If he or she regards the hospitality offered as unsuitable or excessive, you may be asked to refuse the invitation. In particular:
- CMRC employees shall not seek, or accept for themselves or others, any gifts, favors, entertainment, payments, nor shall they seek or accept personal loans other than conventional loans at market rates from financial institutions, or any persons or business organizations that do or seek to do business with or is a competitor of CMRC;
- Strict standards and, if necessary, disclosure are expected from all CMRC employees with respect to gifts, services, discounts, entertainment or considerations of any kind from clients or suppliers. Gifts received by you or your family from CMRC clients or suppliers are to be treated as the property of CMRC;
- Use of clients or suppliers facilities (such as cars, vacation homes, etc.) by CMRC employees (including families and friends) for personal use is strictly prohibited; and
- It is strictly prohibited to accept a gift in cash, or cash equivalent, such as stocks or other forms of marketable securities of any amount as this may contravene applicable share trading, market abuse or insider dealing regulations both here and in other jurisdictions. For the avoidance of any doubt, you should contact your line manager if you are involved in the trading of any marketable securities.
6. Conflicts of Interest
Hospitality given and received is part of the general establishment of good business relationships. In the event you are offered hospitality (other than of a minor nature such as lunch), you should discuss this with your superior before accepting. If he or she regards the hospitality offered as unsuitable or excessive, you may be asked to refuse the invitation. In particular:
- CMRC employees should endeavor to avoid any situation which involves, or may involve, a potential conflict of interest between their personal interests and the interests of CMRC. As in all other aspects of their duties, employees dealing with customers, suppliers, contractors, competitors or any person doing or seeking to do business with CMRC should always act in the best interests of CMRC.
- Each employee shall make prompt and full disclosure in writing to their supervising manager of any situation which may involve a potential conflict of interest.
- Having any direct or indirect personal financial interest in any CMRC project;
- Ownership by an employee or by a member of an employee’s family of a significant interest in any outside enterprise which does or seeks to do business with, or is a competitor of, CMRC;
- Acting as a broker, finder, go-between or otherwise for the benefit of oneself or a third party in transactions involving or potentially involving CMRC or its interests;
- Any other arrangements or circumstances, including via/indirectly through family or other personal relationships, which might dissuade an employee from acting in the best interests of CMRC; and
- Utilizing CMRC funds for personal or immoral, unethical unlawful purposes.
7. Conflicts of Commitment
- With the acceptance of full-time employment (or other arrangement) with CMRC, an employee makes a commitment to CMRC. All employees are expected to devote their primary professional loyalty, time, and efforts to serve CMRC. Employees may sometimes engage in outside professional workto the extent these activities serve CMRC interests as well as those of the participant, and subject to the written approval from CMRC management of such commitments. In all cases, such outside interests should not interfere with the performance of one’s duties to CMRC.
- Employees are expected to demonstrate a high level of expertise at CMRC and as a result may be required on occasion to provide advice to third parties on a consultancy basis. Offers of consultancy work should be notified to CMRC senior management for approval prior to acceptance. In accepting consultancy work, employees will be expected to ensure that the work undertaken does not conflict with CMRC’s objectives or interfere with the performance of their responsibilities within CMRC.
- Potential conflicts of commitment by you or knowledge of a potential conflict of commitment by any other employee must be disclosed to senior management. In coordination with senior management, the relevant director or relevant person within CMRC should resolve related conflicts of commitment, and update the respective CMRC HR Department accordingly.
8. Confidential Information
- Given the sensitive nature of CMRC business and, in particular, the benefits of the special relationship that CMRC shares with the Government of Abu Dhabi, it is essential that any Confidential Information (as defined below) provided to, or observed by, employees (whether in person, over the telephone, via email, or in any other form, regardless of whether it is expressly stated as being confidential) is not to be disclosed to a non-CMRC employee without first receiving express permission from the individual’s immediate supervisor or the Legal Department. Moreover, Confidential Information should only be shared internally within CMRC or with professional advisers on a need-to-know basis. If there is any doubt as to whether or not any information can be disclosed or is confidential in nature, it is the responsibility of each individual employee to check with his or her immediate supervisor or with the Legal Department prior to making such disclosure. All employees should use their discretion when discussing work related matters in casual settings when away from the office (for example, while at lunch, on a plane, at home, etc.) or even within the office building (such as in elevators).
- If required by effect of law or for any other purpose permitted by the Company in writing, when disclosing Confidential Information to a third party (i.e. a person or entity not within or employed directly by CMRC), for example, in connection with a new or existing project or anything related to your work or the business of CMRC, you must ensure that the recipient of such Confidential Information treats that information confidentially and, when necessary, has entered into an appropriate confidentiality arrangement with CMRC. An agreement must be entered prior to making any disclosure of Confidential Information to a third party. The first form is a “one-way” confidentiality letter and the other form is a “reciprocal” confidentiality agreement. The appropriate form should be used based on whether or not Confidential Information will be shared only by CMRC, in which case a one-way letter is appropriate, or if the exchange of Confidential Information will be mutual, in which case the reciprocal agreement is appropriate. The Legal Department should approve all initial drafts of such forms prior to their distribution. Furthermore, all confidentiality agreements (whether or not using our forms) have to be reviewed and approved by the Legal Department.
- The confidentiality provisions contained in this Handbook shall remain in full force and effect notwithstanding any termination or expiry of an employee’s contract, engagement or employment with CMRC. Any breach by an employee of these rules may result in immediate discharge and/or legal proceedings.
- Confidential Information means all information of whatever nature relating wholly or partly to employment or the affairs of CMRC, which:
- is supplied by or on behalf of CMRC in writing or orally and whether before or after the date of an employee’s engagement;
- is obtained by the employee in writing or orally, through or following discussions with the management, employees, clients, suppliers, agents or advisers of CMRC;
- is acquired by observation by the employee at the offices or other premises of CMRC or its suppliers or clients; or
- consists of any reports, analyses, compilations, studies or other documents prepared by, on behalf of, or for, CMRC.
- The confidential information of third parties on CMRC premises should also be protected. It is forbidden to bring confidential material of a third party to CMRC offices without that party’s written permission. Illegal copying of computer software programs is also prohibited.
- Confidential Information including patient information, or practice issues in public places including social media even when no names are used. This caution applies to social networking sites, e.g. Facebook, blogs, emails, Twitter and other electronic communication media.
9. Interaction With and Treatment of Colleagues
- Treat your colleagues with respect and work with them in a professional, collaborative and co-operative manner. It is important to recognize that others have a right to hold different opinions.
- Acknowledge the experience and expertise of colleagues, and respect the contribution of all practitioners and staff involved in the care of a patient and in the development of CMRC.
- Communicate clearly, effectively, respectfully and promptly with other nurses and health care professionals caring for the patient especially when handing over or transferring care to another member of the nursing staff, health professional, practitioner or service provider of CMRC.
- Your behavior towards colleagues should always be respectful and not include dismissiveness, indifference, bullying, verbally abuse, harassment or discrimination. Do not discuss colleagues in public places or on social media. This caution applies to social networking sites, e.g. Facebook, blogs, emails, Twitter and other electronic communication mediums.
- Work with your colleagues, the Nurse Manager and management of CMRC to monitor the quality of your work and maintain the safety of those in your care.
- Support, mentor and teach colleagues and other members of the health care team, especially those who are not as experienced as you.
- Intervene to stop unsafe, incompetent, unethical or unlawful practice. Discuss the issues with those involved. Report to the Nurse Manager or management of CMRC at the earliest opportunity. Do not discuss, gossip or talk to other colleagues or third person(s). Take action to safeguard the patients.
10. Respect towards Patients
- Abide by the HAAD Code of Conduct and shall act in accordance with the scope of practice and services for which they you been engaged for.
- Failure to attend duty at the times assigned is a serious offence considering the nature of services and the necessity of care for the patients for which CMRC has been engaged. Your moral duty towards the patient is to ensure that at no point is the patient put at risk. Failure to show up to duty without prior approval from the Nurse Manager or Management of CMRC constitutes a breach of this code of conduct and shall cause you to be subject to the Disciplinary Code.
- Respect the dignity of patients and their families and treat them with kindness and consideration. Identify yourself and your role in their care.
- Take all necessary precautions and steps to ensure that the environment and provision of care allows patients, their families and representatives to maintain their privacy and dignity. Do not prejudice the care you give because you believe a patient’s behavior or the actions of their family or representatives contributed to their condition.
- Do not impose your political, religious and cultural beliefs on patient, and intervene if you see other staff members of CMRC doing this.
- Take steps to minimize risk and ensure your care does not harm the health or safety of patients
- Ensure care provided is culturally appropriate and acceptable to patients and in accordance with the local cultural customs and beliefs. You should try to promote access to services which meet the religious, cultural and political beliefs of the patient (eg. Recognizing prayer times, dress code etc..)
- Respect the patient’s right to complain and respond by working with them to resolve the issue.
11. Provision of Care
- Be readily accessible to patients and colleagues when you are on duty.
- Keep your professional knowledge and skills up to date.
- Recognize and work within the limits of your competence and your scope of practice.
- Ask for advice and assistance from colleagues especially when care may be compromised by your lack of knowledge or skill.
12. Professional Behavior
- You must declare any personal, financial or commercial interest which could compromise your professional judgment.
- Do not misuse your professional position to promote or sell products or services for personal gain.
- Respect the possessions and property of CMRC and patients in your care. As a member of CMRC you may have access to money, information, medical equipment and supplies. Your ethical responsibility and commitment under this Code of Conduct is to ensure that you do not engage, purport to engage or assist in theft from CMRC, other CMRC staff (your colleagues), the management, patients, patient’s family members or representatives, suppliers or any other persons. Such behavior is considered illegal under the UAE law and shall cause the employee to be subject to the disciplinary code.
- Maintain professional boundaries between yourself and the patient and their family members and representatives involved in their care. It is forbidden to engage in sexual or intimate behavior or relationships with patients in your care or with those close to them. Keep your personal and professional lives separate as far as possible. Avoid online relationships with current or former patients. Do not use social media or electronic communication to build or pursue relationships with patients, their family members or representatives.
13. Termination of the contract of Employment as per The UAE Labor Law article 120
An employer may dismiss a worker without notice in any of the following cases:
- If the worker adopts a false identity or nationality or submits forged certificates or documents;
- If the worker is engaged on probation and is dismissed during the probationary period or on its expiry;
- If the worker makes a mistake resulting in substantial material loss for the employer, on condition that the latter notifies the labor department of the incident within 48 hours of his becoming aware of its occurrence;
- If the worker disobeys instructions respecting industrial safety or the safety of the workplace, on condition that such instruction are in writing and have been posted up at a conspicuous place and, in the case of an illiterate worker, that he has been acquainted with them orally;
- If the worker does not perform his basic duties under the contract of employment and persists in violating them despite the fact that he has been the subject of a written investigation for this reason and that he has been warned that he will be dismissed if such behavior continues;
- If the worker reveals any secret of the establishment in which he is employed;
- If the worker is finally sentenced by a competent court for an offence involving honor, honesty or public morals;
- If the worker is found in a state of drunkenness or under the influence of a drug during working hours,
- If, while working, the worker assaults the employer, the responsible manager or any of his work mates,
- If worker absents from his work without a valid reason for more than 20 non-consecutive days, or more that seven consecutive days.
