1 Introduction
We need to ensure that in cases of emergencies and crises the relevant persons at Colosseum Dental Group (“Group” or “we”) can be reached, and appropriate actions can be taken. This Crisis Management Procedure shall serve as (i) central document that contains all contact details of all relevant persons as well as (ii) the procedure that must be followed in case of an emergency and/or crisis.
All events that severely threaten the reputation or the business activities of our Group and which require immediate action are considered emergencies/crises under this procedure. Examples of emergencies/crises are serious medical malpractice, the death of a patient, dawn raids by the authorities, severe IT system failures, (threatened or actual) negative publicity in the (social) media, natural disasters that damage our key infrastructure, sudden death of key employees, just to name a few.
It is important that this procedure is followed in cases of emergencies and crises. The reputation of our Group can be seriously damaged by a poorly managed crisis and this procedure shall ensure that the appropriate steps are taken, and all necessary stakeholders are involved.
2 What to Do in Case of an Emergency?
2.1 Country Level
2.1.1 Country Headquarter
In case of an (general) emergency/crisis at country level, the Local Chief Executive Officer must be contacted immediately by telephone after becoming aware of the emergency. If the Local Chief Executive Officer cannot be reached within 10 minutes, the Local Chief Financial Officer must be contacted by telephone. If the Local Chief Financial Officer cannot be reached within 10 minutes, the Local Communications Director or Local General Counsel (if any) must be contacted by telephone. If none of the above persons can be reached, within 30 minutes, an e-mail shall be sent to all these persons informing them of the emergency. In addition, the person reporting the emergency shall contact the Group General Counsel and, if he or she cannot be reached within 10 minutes, the Group Chief Financial Officer.
If an emergency/crisis, in the reasonable opinion of the country leadership team, is of a serious nature, it shall immediately inform the Colosseum Group Office (consisting of the Group Chief Executive Officer, the Group Chief Financial Officer and the Head of Corporate Communications) about the emergency/crisis and the proposed steps to address the matter.
In case of a dawn raid (meaning an unannounced inspection or visit) by any authority, the Local General Counsel (if any) must be contacted immediately by telephone. If he or she cannot be reached within 10 minutes or if there is no Local General Counsel, the county’s external lawyer must be contacted. In addition, the procedure in case of a (general) emergency/crisis must be followed. If possible, the representatives of the authorities should be placed in a meeting room and asked whether they would be willing to delay their inspection until the Local Chief Executive Officer, Local Chief Financial Officer, Local General Counsel (if any) and/or our external lawyer has arrived.
In case of any emergency/crisis relating to our IT infrastructure, the Local IT Department must be contacted immediately by telephone after becoming aware of the emergency. If the Local IT Department cannot be reached within 10 minutes, the Local Chief Financial Officer must be contacted by telephone. If the Local Chief Financial Officer cannot be reached within 10 minutes, the Group Chief Information Officer must be contacted by telephone. If none of the above persons can be reached, within 20 minutes, an e-mail shall be sent to all these persons informing them of the emergency/crisis and the person reporting the emergency shall proceed in accordance with the contact rules for an (general) emergency/crisis.
In case of any emergency relating to data protection, the Local Data Protection Officer (DPO) must be contacted immediately by telephone after becoming aware of the emergency. If the Local Data Protection Officer cannot be reached within 10 minutes, the Local Chief Financial Officer must be contacted by telephone. If the Local Chief Financial Officer cannot be reached within 10 minutes, the Group General Counsel must be contacted by telephone. If none of the above persons can be reached, within 30 minutes, an e-mail shall be sent to all these persons informing them of the emergency/crisis and the person reporting the emergency shall proceed in accordance with the contact rules for a (general) emergency/crisis.
2.1.2 Clinic
In case of an emergency/crisis at clinic level, the Clinic Manager must be contacted immediately by telephone after becoming aware of the emergency. If the Clinic Manager cannot be reached within 10 minutes, the Area Manager must be contacted by telephone. If the Area Manager cannot be reached within 10 minutes, an e-mail shall be sent to the Clinic Manager and the Area Manager informing them of the emergency. Thereafter, the procedure in case of a (general) emergency/crisis for Country Headquarters must be followed.
2.2 Group Level
In case of an (general) emergency/crisis at Group level, the Group Chief Executive Officer must be contacted immediately by telephone after becoming aware of the emergency. If the Group Chief Executive Officer cannot be reached within 10 minutes, the Group Chief Financial Officer must be contacted by telephone. If the Group Chief Financial Officer cannot be reached within 10 minutes, the Chief Dentist must be contacted by telephone. If the Chief Dentist cannot be reached within 10 minutes, the Group General Counsel must be contacted by telephone. If none of the above persons can be reached, within 30 minutes, (i) an e-mail shall be sent to all these persons informing them of the emergency/crisis and (ii) the Head of Corporate Communications shall be contacted thereafter. If the Head of Corporate Communications can also not be reached, the person reporting the emergency shall start again trying to reach the persons mentioned above.
In case of a dawn raid (meaning an unannounced inspection or visit) by any authority, the Group General Counsel shall be contacted immediately by telephone. If the Group General Counsel cannot be reached within 10 minutes, (i) the Group Chief Executive Officer must be contacted by telephone and (ii) an e-mail must be sent to the Group General Counsel informing him or her of the dawn raid. In addition, our external lawyer must be contacted immediately. If the Group Chief Executive Officer cannot be reached within 10 minutes, the Group Chief Financial Officer must be contacted by telephone. If the Group Chief Financial Officer cannot be reached within 10 minutes, the Head of Corporate Communications must be contacted by telephone. If the Head of Corporate Communications cannot be reached within 10 minutes, the person confronted with the authorities shall again call the Group General Counsel. If possible, the representatives of the authorities should be placed in a meeting room and asked whether they would be willing to delay their inspection until the Group Chief Executive Officer, Group Chief Financial Officer, Group General Counsel and/or our external lawyer has arrived.
In case of any emergency/crisis relating to our IT infrastructure, the Group Chief Information Officer must be contacted immediately by telephone after becoming aware of the emergency. If the Group Chief Information Officer cannot be reached within 10 minutes, the Group Chief Financial Officer must be contacted by telephone. If the Group Chief Financial Officer cannot be reached within 10 minutes, the Group General Counsel must be contacted by telephone. If none of the above persons can be reached within 30 minutes, an e-mail shall be sent to all these persons informing them of the emergency/crisis and the person reporting the emergency shall proceed in accordance with the contact rules for a (general) emergency/crisis.
3 External Experts
Every country organization shall appoint two external experts, a lawyer as well as a communication expert, who are on stand-by and can be contacted if we need assistance in case of emergencies/crises. Each expert shall ensure that there is a back-up expert in case he or she is absent. The contact details of these experts can be found in Annex 2.
The external lawyer shall assist in cases of dawn raids by authorities, such as the data protection, health, tax or competition authorities. The communication expert shall assist in cases which have a reputational impact on our Group and require communications to the public and/or our patients.
4 Crisis Management Team
4.1 Country Level
The Local Chief Executive Officer, or in case of his/her unavailability, the Local Chief Financial Officer, shall compile a crisis management team. Such crisis management team shall consist of the Local Chief Executive Officer, the senior executive responsible for the relevant line of business, the Local Communications Director and the Local General Counsel (if any). Depending on the nature of the crisis, the Local Chief Executive Officer can include additional functions in the crisis management team. In case the crisis is of a serious nature and needs to be escalated to Colosseum Group Office, the crisis management team shall also work closely, and update regularly, the Colosseum Group Office.
The crisis management team is responsible for (i) developing an action plan addressing the crisis, (ii) developing a communication strategy, (iii) interacting with media and the public, and (iv) making public statements on behalf of the company belonging to Colosseum Dental Group. If necessary, the crisis management team shall involve the local external communication expert and/or the local external lawyer. The crisis management team shall keep the Colosseum Group Office updated on a regular basis.
4.2 Group Level
The Group Chief Executive Officer, or in case of his/her unavailability, the Group Chief Financial Officer, shall compile a crisis management team. Such crisis management team shall consist of the Group Chief Executive Officer, the Group Financial Officer, the Head of Corporate Communications and the Group General Counsel. Depending on the nature of the crisis, the Group Chief Executive Officer can include additional functions in the crisis management team.
The crisis management team is responsible for (i) developing an action plan addressing the crisis, (ii) developing a communication strategy, (iii) interacting with media and the public, and (iv) making public statements on behalf of Colosseum Dental Group. If necessary, the crisis management team shall involve the local external communication expert and/or the local external counsel.
5 Principles of Crisis Communication
The (internal and external) communication in case of a crisis is prepared on a case-by-case basis by the crisis management team and, if necessary, with the help of the external communication expert and/or the local external lawyer. All external communication is routed through the Local Chief Executive Officer (in case of a country crisis) or the Group Chief Executive Officer (in case of a Group crisis). No other employee of Colosseum Dental Group may make any statements whatsoever, unless such employee has been explicitly authorized to make such statements. If an employee of Colosseum Dental Group receives an information request, such request shall be immediately referred to the Local Head of Communications (in case of a country crisis) or the Head of Corporate Communications (in case of a Group crisis).
When we communicate to the public, we adhere to the following principles: (i) speed is key, (ii) we take the matter seriously, (iii) we are respectful, (iv) we communicate in a clear, open and transparent way, (v) we are one group and communicate with one voice, (vi) we are sympathetic, (vii) we take ownership, and (viii) we provide updates on a regular basis.
6 Approval and Entry into Force
This Crisis Management Procedure was approved by the Executive Committee of the Colosseum Dental Group on 29 August 2023 and entered into force on 29 August 2023.
Annex 1 – Flow Chart
General Emergency/Crisis Country Headquarter Level
General Emergency/Crisis Clinic Level
Dawn Raid Country Level
IT Emergency Country Level
Data Protection Emergency Country Level
General Emergency/Crisis Group Level
Dawn Raid Group Level
IT Emergency Group Level
