Code of Conduct and Business Ethics

Medic Relief Pty Ltd – ABN 72 609 108 376 – CODE OF CONDUCT AND BUSINESS ETHICS

Introduction

Medic Relief Pty Ltd (“MedicRelief”) has adopted this Code of Conduct and Business Ethics (“Code”) regarding interactions with patients, Health Care Providers (“HCP”) and our business conduct within the industry generally. All interactions between MedicRelief 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.

MedicRelief will ensure that all Company Representatives are appropriately trained on the requirements of this Code. MedicRelief 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 MedicRelief and for Company Representatives. This Code incorporates principles set out to:

  • Conduct his/her responsibilities in compliance with this Code;
  • Comply with MedicRelief’s Corporate Compliance Program and any written policies, procedures and other guidelines;
  • Protect MedicRelief’s reputation by actively supporting ethical behaviour;
  • Promptly report any potential or actual non-compliance; and
  • Fully and honestly cooperate in any investigation of alleged violation of this Code or MedicRelief’s Compliance Program Policies and Procedures.


    • MedicRelief’s Corporate Compliance Program

    MedicRelief is committed to conducting its business in compliance with the Federal and state laws, regulations and other requirements that govern our operations. MedicRelief 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, MedicRelief 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. MedicRelief has a strict non-retaliation policy to protect MedicRelief Representatives who raise concerns in good faith. No action of reprisal or retaliation will be taken against any MedicRelief 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. MedicRelief is committed to the education of its Company Representatives on issues related to corporate compliance. As such, MedicRelief 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 MedicRelief. 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

    MedicRelief is committed to full compliance with all International, Federal and State laws and regulations applicable to our business, including but not limited to, the Therapeutic Goods Administration (TGA); Medicines and Healthcare products Regulatory Agency (MHRA); Federal Food, Drug and Cosmetic Act; Food and Drug Administration (FDA); Australian Competition and Consumer Commission (ACCC); Anti-Kickback Statutes; and patient privacy and confidentiality.

    Fraudulent Conduct is Prohibited

    MedicRelief does not tolerate fraud and is committed to the rigorous investigation of any suspected cases of fraud. Should any MedicRelief Representative believe they have good reason to suspect a colleague or other individual is engaged in fraud or an offence involving MedicRelief or a serious infringement of the Code, he or she should report such unethical action his or her or supervisor to the Chief Compliance Officer (CCO).

    Privacy Requirements

    MedicRelief respects the confidential nature of patient health information. Therefore, MedicRelief must comply with all Federal and state health information privacy and security laws. Generally, unless otherwise permitted or required by law, MedicRelief will not disclose patient health information without prior authorisation. MedicRelief 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 unauthorised access, and retained only for as long as it is necessary. MedicRelief has adopted a number of additional Compliance Program Policies and Procedures addressing privacy issues that may affect its business activities.

    Sanctioned/Excluded Individuals and Entities

    Overseas, Federal government or other state agencies may pay for MedicRelief’s products and services. Individuals and/or entities may be excluded, debarred or suspended from participating in Federal or state programs for various reasons, including inappropriate use of Federal or state funds. MedicRelief will not knowingly employ or contract with any individual or business which is excluded, debarred or suspended from participating in any government program. Generally:

  • Promotional material and communications must be accurate, balanced and not misleading in any respect. Claims must be compliant with medical, legal and regulatory standards.
  • All promotional material must be reviewed and approved by MedicRelief before use.
  • All promotional and advertising activities targeted toward patients will be in compliance with laws, regulations and MedicRelief Policies and Procedures.


    • 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 MedicRelief’s products or services. MedicRelief’s interactions with healthcare professionals, organisations and other authorities must be made in compliance with applicable laws, regulations, and MedicRelief Compliance Policies and Procedures. Our general policy can be expressed in two main points:

  • MedicRelief 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 MedicRelief 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.


    • For any questions or notice, please contact us at:

    MedicRelief Pty Ltd – ABN: 72 609 108 376

    Email: admin@medicrelief.com

    Last update: 05 April 2020