1. Purpose and Scope
This Group Code of Conduct (the “Code”) shall provide a framework for Colosseum Dental Group’s (the “Group”) Employees and the business partners of our business principles and ethical standards that we expect to be respected in our daily activities. The Code shall convey the principles and values of our Group. It shall ensure that we live up to our social corporate responsibility in everything we do so that we can be proud of our Group’s culture and achievements. „Employees“ in the sense of this Code of Conduct includes our directors, managers, employees, other staff as well as consultant dentists.
If we all live by the principles and values outlined in this Code, we will act in a responsible and compliant manner even if the Code may not provide a specific answer to every situation we may encounter during our daily work. Hence, we expect our employees to use good judgement and reflect on the general principles and values of our Group when facing new and unfamiliar situations.
2. Compliance with this Code of Conduct
This Code applies to all employees and business partners of our Group, regardless of their status, location and the nature of their work. Certain topics covered by this Code will be further governed by specific regulations that further detail the behaviour expected for these topics. Violations of this Code and any further regulation will not be tolerated, and disciplinary action may be taken in cases of breaches. Failure to take action as is requiredis seen as unethical and also regarded as a contravention of the Code.
3. Health and Safety
Our people are our greatest strength. We are, therefore, committed to creating a safe and friendly working environment where every employee feels respected and can contribute to achieving the best possible patient satisfaction. We adhere to the highest professional standards when it comes to patient safety. We have built a dedicated training facility – the Colosseum Academy – where we provide training to our Employees to guarantee the same quality level across our Group. Everyone at our Group must understand his or her personal contribution and impact on the outcome we deliver to our patients. Our internal safety processes and procedures are monitored, reviewed and adapted, and our Employees are trained on safety issues to ensure that our patients can benefit from safe and effective medical treatments.
We take our responsibility as a healthcare provider serious. We are in close collaboration with the national health authorities as well as pharmaceutical and medical devices companies to report adverse events occurring in our daily practice. We aim to help improve the professional equipment we need to provide high-quality dental services and minimize the risk of invasive treatment as far as possible.
4. Interactions with Third Parties
Patients are the foundation of our success, and our Group aimsto improve patients’ well- being by providing high-quality dental services. When it comes to the treatment of our patients, we expect every Employee of our Group to apply the highest professional standards across all services offered by our Group. Our patients need to be fully informed of all (medical and financial) aspects of the recommended treatment to make an informed decision. We respect the patients’ wishes and rights at all times – provided these are in line with medical and ethical standards – and all medical treatments performed by our Group are in the best interest of our patients. We do not recommend or perform unnecessary treatments and are committed to fair and transparent billing practices.
By continually monitoring, measuring and adapting our services across the Group, we strive to improve patient safety and satisfaction to provide the best possible dental care. Complaints raised by our patients are taken seriously, thoroughly investigated and discussed with the patient who raised the complaint.
b. Industry Partners
For the Colosseum Dental Group to be able to provide high-quality dental services, we need first-class dental equipment. It is our policy to only work with reliable, trusted and reputable industry partners which share the same values as we do. We choose our industry partners and products based on their ability to fulfil our patients’ medical needs, the quality of products, their reliability and reputation, the partners’values, their compliance program and price. We expect from our partners to comply with this Code, our Supplier Code of Conduct as well as all applicable laws and to adhere to the highest ethical standards.
To foster trust in the relationship between our industry partners and our Group, we support our partners concerning their transparency reporting under applicable laws and regulations.
We see competition as a good thing. Competition helps us to question our current practices, continuously improve and expand our services and stay patient-oriented as we want always to stay ahead of our competition. The Colosseum Dental Group is committed to fair competition, and we aim to compete based on the merits of our services. We do neither engage in unfair or unethical business practices nor anti-competitive discussions or agreements with our competitors.
d. National Authorities and Public Officials
As we work in a highly regulated industry, interactions with authorities, such as national health authorities, and public officials are part of our business. A public official is someone in a position of official authority or acting in a public official capacity. Examples of public officials are officers in health authorities, reimbursement bodies or government authorities as well as parliament members.
Also, when interacting with national authorities and/or public officials, we abstain from any behaviour that might be perceived as illegitimate behaviour to gain an improper advantage. We do not try to gain an improper or unfair advantage by offering or promising anything of value to a public official to influence his or her decision. Likewise, we do not follow such a request made by a public official.
5. Compliance with Laws and Regulations
The Colosseum Dental Group is committed to an ethical, legal and compliant way of doing business. As an international group of companies, we are subject to different national laws, regulations and customs. Not following these laws and regulations may lead to serious adverse consequences for our Group, its Employees and our reputation. Our Employees are, therefore, responsible for understanding and respecting the applicable laws and regulations in their area of activity. We also expect from our business partners to act ethically and in compliance with the applicable legal framework when doing business with us.
6. Business Courtesies and Gifts
The Colosseum Dental Group is committed to fair and ethical business practices. Business courtesies – such as invitations, gifts or meals – are accepted business practices in most countries we operate in. However, we strictly prohibit any behaviour that might be perceived as unduly influencing another person to gain an improper advantage. We do not try to gain an improper or unfair advantage by offering or promising anything of value to someone to influence his or her decision. Likewise, we expect our suppliers and business partners not to unduly influence our Employees to gain an improper advantage at the expense of our Group.
Employees may not participate in events organized by our industry partners that have an entertainment character and do not focus on medical education or training.
7. Discrimination and Harassment free Environment
Passion for dental care and the best patient experience is paramount to us. This not only requires us to apply the highest professional standards when it comes to the treatment of our patients but also to provide our employees with a safe, respectful and friendly working environment, free from harassment and discrimination. We do not tolerate harassment or discrimination of any kind, be it towards patients or Employees. We also do not tolerate any behaviour that creates a hostile working environment, aggressive pressure or intimidation. Harassment or discrimination in the meaning of this Code includes any unwanted or unwelcome attention or discriminatory conduct based on race, colour, religion, citizenship, national origin, gender, sexual orientation, disability, pregnancy or other characteristics provided by law. Any such harassment of patients or Employees will result in disciplinary action. If you have been harassed or discriminated, please refer to the Reporting & Investigations Policy for obtaining more information on how to raise a complaint.
8. Confidentiality and Privacy
All our Employees must understand the importance of privacy, data protection and confidentiality. Our Group is committed to respect and maintain the privacy and confidentiality of patients and Employees alike. We do not tolerate the invasion of our patients’ privacy by our Employees. We restrict access to patient information as appropriate and use it only as necessary for legitimate business purposes. Our collection, use and storage of such information complies with the laws and regulations of the countries we operate in. For more information on privacy, data protection and IT security, please refer to our Group Data Protection Policy.
All Employees, as well as the consultants of our Group, must protect confidential patient data, company and business information and not disclose such information to any third party outside the Group. In particular, the confidentiality of our patients’ medical records is paramount to maintain the patients’ trust in our services and our Group.
9. Asset Protection
Ethical conduct also includes careful use of resources and our assets. We provide our employees with state of the art infrastructure and dental equipment to enable them to provide first-class dental services. We expect our Employees to use such company equipment with diligence and care and take reasonable precautions to protect such equipment from loss, damage or theft. Dental equipment shall always be used and maintained by their instructions and processes to ensure proper use and patient safety. Such Equipment must not be used or removed for any other purpose than purposes of the Group, in particular not for private or third-party purposes.
10. Conflicts of Interest
We expect our employees to avoid any conflict of interest between their own interests and those of the Group. When making a decision affecting the Group, personal interests may not adversely affect such decision at the expense of Colosseum Dental Group, and Employees should always consider our Group’s best interests.
A conflict of interest arises when a person’s private interests interfereor have the appearance of interfering, in any way with the legitimate interests of the Colosseum Dental Group. Non-exhaustive examples of such conflicts of interest are (a) engaging in any activity that competes with our Group; (b) engaging the services of family members or friends solely based on the personal relationship; (c) purchasing equipment from a company in which the decision making Employee has an interest in. Conflicts of interest are strictly prohibited unless approved by the line manager.
11. Community and Environment
As a good neighbour, we expect our employees and team members to behave in a way that respects, protects and promotes the welfare of the communities in which we operate.
We recognize our responsibility towards the environment and, therefore, we use our natural resources in a responsible, sustainable and effective manner. We ensure sustainable waste management and recycling.
12. Use of Social Media
The Colosseum Dental Group uses social media, such as LinkedIn, Instagram, Facebook, to communicate with our patients, employees, business partners and other stakeholders. We see social media as a powerful tool to stay connected and interact with, as well as provide information to, our different stakeholders. Authorized Employees of our Group may only edit the official social media channels of the Colosseum Dental Group. Any posts on such channels must always comply with our values, this Code and all other regulations of the Group.
We appreciate that our Employees also use social media in their private life. As every post made by an employee in his/her private life may also potentially affect the Colosseum Dental Group as an employer, we encourage Employees to responsibly use social media and use common sense and sound judgement when posting any material and/or information on social media. It is strictly prohibited to post any work-related confidential information on social media. If any patient information, such as patient pictures, shall be posted on social media, the written consent of the patient needs to be obtained before any such post. Besides, we do not tolerate that Employees expose other Employees or patients on social media channels. We generally expect from our Employees to responsibly use social media and adhere to the values and conduct described in this Code.
For further information on the use of social media, please refer to our Social Media Guidelines.
13. Education and Training
A critical element of our compliance with this Code of Conduct is the education and training of our employees on their legal and ethical obligations. Colosseum is committed to taking all necessary and appropriate stepsto communicate our standards and procedures to all Employees effectively. Ongoing training programs include live meetings or videoconferences on CDG level and local level. It also includes webinars/on-line courses for newly joining Employees and regular refresher courses. Moreover, the training program is regularly reviewed and updated, and additional areas of training are identified on an “as needed” basis.
14. Reporting Concerns
We encourage every employee of the Group to report any concern relating to a non-compliant behaviour to his/her line manager, the human resources department or the Group General Counsel. Any concern raised, and any complaint filed by an Employee will be taken seriously and will be investigated. The Board of Directors, as well as the Leadership of the Colosseum Dental Group, will support any employee who in good faith raises any concerns or reports a suspected breach of this Code. The Colosseum Dental Group does not tolerate any retaliatory action if concerns are raised in good faith.
For further information on raising concerns and how complaints are being investigated, please refer to our Reporting & Investigations Policy.
15. Assistance in Case of Questions
If you have any questions about our values, this Code or the correct behaviour in a specific situation, you can always approach your line manager, the human resources department or the Group General Counsel and ask for help. We are committed to assisting our employees in their efforts to adhere to our Group’s Code of Conduct.
16. Approval and Entry into Force
This Code of Conduct was approved by the Board of Directors of the Colosseum Dental Group on 04 September 2020 and entered into force on 1 October 2020.