PDCL_Code of Conduct

Padma Diagnostic
Center Limited
Code of Conduct (CoC)
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S.L. Contents Page
Number
1 The Purpose of Code of Conduct 4
2 Who must follow the code of conduct? 4
3 General Principles of Code of Conduct 5
3.1 Service to users 5
3.2 Respect for people 5
3.3 Respecting the contractual and legal obligations 5
3.4 Equal rights 5
3.5 Transparency 5
3.6 Loyalty 5
3.7 Confidentiality 5
3.8 Partnership and co‐operation 5
3.9 Corporate culture 6
4 General Rules of Code of Conduct 6
4.1 Discrimination 6
4.2 Mobbing/Bullying 7
4.3 Sexual harassment 7
4.4 Corruption 7
4.5 Activities outside work 7
4.6 Information 8
4.7 Use and protection of assets 8
4.8 Conflict of interest 8
4.9 Drugs and Alcohol 8
4.10 Financial Integrity and Responsibility 8
5 How to proceed in case of breach of Code of Conduct? 9
5.1. a. Ask for a personal conversation 9
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5.1. b. Write a personal letter 9
5.1. c. Evidence and look for witnesses 9
5.1. d. Consult the compliance officer or any superior of trust 9
5.2 Investigation 9
5.3 Confidentiality 9
5.4 False complaint 9
6 Checklists for Code of Conduct 10
6.1 For all employees 10
6.2 For Department Head 10
6.3 For Head of Human Resources 10
6.4 For Management 11
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1. The Purpose of Code of Conduct
The objective of PDCL is to promote health care industry in Bangladesh and to make lives easier
for everyone – and doing so in a socially, ecologically, and economically sustainable way.
Moreover, our users trust us with their personal information and preserving that trust requires
us to respect their privacy and security. Finally, to build an organization that stands the test of
time, we need to do things right – this means we must act in accordance with law, deal fairly and
honorably, create an inclusive and open environment, treat everyone with respect, and foster
innovation.
We recognize that everything we do in PDCL should be measured against the highest possible
standards of ethical business conduct. The Code of Conduct (CoC) has been designed to capture
the set of values we believe in and strive to achieve.
This code is subject to change and may be amended, supplemented or superseded by one or
more separate policies. If any part of this code conflicts with local laws or regulations, only the
sections of this code permitted by applicable laws and regulations will apply.
2. Who must follow the code of conduct?
We expect all our employees and board members to know and follow the Code of Conduct.
Failure to comply with the code can result in disciplinary action, including termination of
employment. Moreover, while the Code is specifically written for PDCL employees and its board
members, we expect PDCL contractors, consultants, and others who may be temporarily assigned
to perform work or services for PDCL to follow the code in connection with their work for us.
Failure of a PDCL contractor, consultant, or other covered service provider to follow the code can
result in termination of their relationship with PDCL.
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3. General Principles of Code of Conduct
3.1 Service to users: Our users expect a high quality of service. All employees should be
responsive to user’s queries and keep the user experience in mind before taking any decision.
Users are entitled to privacy of information that they share with us.
3.2 Respect for people: All PDCL employees are entitled to fair, courteous and respectful
treatment by their superiors, subordinates, and peers. PDCL values the individuality, diversity
and creative potential that each employee brings into the organization and which help to fulfil
PDCL purpose and realize its vision.
3.3 Respecting the contractual and legal obligations: Employees shall fulfill their contractual
commitments. They are expected to respect the laws applicable.
3.4 Equal rights: Employees, in their work with other people, shall not discriminate based on
gender, colour, religion, culture, education, social status, disability, age, sexual orientation, family
status or nationality.
3.5 Transparency: Employees shall make sure that their actions and motives are understandable
and comprehensible.
3.6 Loyalty: Employees shall acknowledge the purpose, vision and internal regulations of PDCL
and be loyal to the foundation. This also includes providing constructive criticism, which
employees should express openly and in an appropriate manner within PDCL.
3.7 Confidentiality: all business information must be handled confidentially whenever its nature
demands discretion or if it is explicitly required.
3.8 Partnership and co‐operation: Co‐operation with partners, vendors and target groups should
always be fair, reliable and based on trust, honesty, and mutual respect. The same also applies
to the behaviour among employees, whereby a constructive approach to conflict management
represents a key component.
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3.9 Corporate culture: Employees understand that, with their work and behaviour, they all
contribute to the image building of the organization. Employees should be especially careful
about what they share on social media (like Facebook).
4. General Rules of Code of Conduct:
✓ Each employee agrees with the CoC and is willing to comply. Hence, all employees shall
conduct themselves in accordance with the letter and the spirit of these principles and rules.
The CoC is an integral part of the employment contract. Non‐compliance with internal rules
will lead to disciplinary action.
✓ Employees involved in the recruitment of staff must ensure that appointments are made
based on a person’s ability and potential in relation to the job requirements. To avoid
accusation of bias, these employees must not be involved in any appointment or other
decisions regarding promotion, development or salary etc. of employees to whom they are
related, or with whom they have a close personal relationship.
✓ The executive director and each department director are responsible for implementing the
Code of Conduct within their teams. The role, accountability and obligations must be made
clear and understandable to all newly appointed staff. New employees must be given full
information about internal rules and regulations as well as assistance in case of doubt.
Superiors must be aware that they are responsible for fostering a positive, motivating
working environment and encouraging team work, preventing de‐motivation, discrimination,
and fraud.
✓ In case of an actual or suspected breach of the CoC, supervisors are obliged to take the
problem seriously, investigate the case immediately and, if required, take appropriate steps.
4.1 Discrimination: All actions or statements that put individuals of different origin, nationality,
colour, gender, religion, or other relevant criteria such as looks, disability, age, sexual
orientation etc. at a disadvantage, humiliate or ridicule them will be regarded as acts of
discrimination. These actions are not tolerated towards colleagues within PDCL, nor towards
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colleagues in partner institutions. Employment in PDCL is based solely upon individual merit
and qualifications directly related to professional competence.
4.2 Mobbing/Bullying: Mobbing/bullying is the systematic exclusion and humiliation of someone
by one or more persons. Such hostile conduct can occur repeatedly and over an extended
period of time. A simple argument or conflict, as may occasionally happen in any work
situation, is not considered mobbing. If the power struggle between the conflicting parties is
even and the conflict is dealt with in an open manner, it is nothing unusual, especially if it
serves as a trigger for positive change. However, typical cases of mobbing are acts that attack
a person’s reputation or social relationships, impair their possibility to communicate, devalue
the quality of their work, or even harm their health.
4.3 Sexual harassment: Any non-consensual sexual comments and behaviour, whether verbal,
physical, mental, or otherwise is considered to be sexual harassment and sexual misconduct.
Any type of friendly close contact with someone is based on mutual agreement between two
persons. Sexual harassment, however, occurs when one person intentionally fails to keep
his/her distance and interacts in an uninvited and unwelcome way. Individual’s experience
‘not keeping their distance’ differently. Hence, there is no general limit of tolerance. This
behaviour implies the degradation of a person based on his or her sex and is offensive,
humiliating, and in many cases threatens the victims. Hence, such behaviour will not be
tolerated or accepted.
4.4 Corruption: The acceptance as well as the handing over of gifts or other advantages (money,
loans, rewards, reduced prices or fares, etc.), from/to (potential) collaborators, public
officials, partner organizations, etc. is prohibited, except for the exchange of symbolic
presents of low value in accordance with local customs of courtesy or when the competent
superior has given his/her written consent. In case of acceptance, the gift is to be used for
business or humanitarian purposes or jointly with other staff members. The procedure is to
be documented. If gifts or advantages must be declined the person making the offer should
be informed of the standards and practices prevailing within PDCL.
4.5 Activities outside work: Employees may not take up other paid or unpaid professional activity
or accept responsibility for such work, without the explicit written consent of the superior.
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Advisory missions of employees, within their field of activity and during their working hours,
require the superior’s consent and will be undertaken on behalf of PDCL. Exceptions are to
be formally laid down in writing. Employees engaged in other paid employment or business
must take approval from the HR Department, in addition to approval from the department
supervisor.
4.6 Information: Openness in the dissemination of information and in decision making is the
norm for all employees within the organization. Information obtained during employment is
not to be used for personal gain or benefit, nor is it to be passed on to others who might use
it in such a way.
4.7 Use and protection of assets: Employees must adhere to high ethical standards and good
business practices, including the careful use and protection of any PDCL assets: financial,
physical, know‐how, etc.
4.8 Conflict of interest: Employees must take sufficient care to separate business from private
spheres. They must immediately reveal conflicts of interest to their superior and resolve them
in a manner that is objectively verifiable by and understandable to all parties involved.
4.9 Drugs and Alcohol: Our position on substance abuse is that it is incompatible with the health
and safety of our employees, and we don’t permit it. Consumption of alcohol within PDCL
premises is banned. Illegal drugs in our offices or at sponsored events are strictly prohibited.
If a manager has reasonable suspicion to believe that an employee’s use of drugs and/or
alcohol may adversely affect the employee’s job performance, or the safety of the employee,
or others in the workplace, the manager may request an alcohol and/or drug screening. A
reasonable suspicion may be based on objective symptoms such as the employee’s
appearance, behaviour, or speech.
4.10 Financial Integrity and Responsibility: A core PDCL value has always been to spend
money wisely. When you submit an expense for reimbursement or spend money on PDCL’s
behalf, make sure that the cost is reasonable, directly related to company business, and
supported by appropriate documentation. Similarly, each time you enter into a business
transaction on PDCL’s behalf, there should be documentation recording that agreement,
approved by the relevant department head. Before you sign something make sure you are
authorized to do so, and that you have studied the contract and understand its implication.
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5. How to proceed in case of breach of Code of Conduct?
Express yourself clearly and confidently if you feel offended by specific comments or actions or
suspect a violation of the CoC by another employee:
5.1.a. Ask for a personal conversation: either one‐to‐one between the parties concerned, or in
the presence of a trusted person.
5.1.b. Write a personal letter: if you feel uncomfortable about a conversation, express yourself
in a letter, listing the remarks and actions you find offensive or suspect are a violation of the
CoC. If the situation does not improve after such a letter, you should write a second one and
send a copy to the compliance officer, the head of human resources at the head office or any
other superior of trust.
5.1.c. Evidence and look for witnesses: write down what happened when, where, and how.
5.1.d. Consult the compliance officer or any superior of trust (verbally or through a
confidential letter), who will treat the matter with absolute confidentiality. There will be no
retaliation for such reporting.
5.2 Investigation: In case a violation of the CoC has been reported and could not be solved in
the above stated manner, a formal investigation will be undertaken by the HR Department or
the superior approached. The procedure is to be documented and the Chief Operating Officer
has to be informed. Those receiving complaints or violation reports are responsible for
acknowledging them personally and rapidly, of informing the plaintiffs of the procedure and of
solving all complaints received within due time. Depending on the severity of the case,
breaches of conduct might be taxed by a written warning, reallocation to a different job, or
even dismissal and legal prosecution of the accused employee. Guidelines for corrective
measures are outlined in the Chapter 5.
5.3 Confidentiality: Confidentiality is guaranteed by the compliance officer, the head of human
resources at the head office, and all superiors involved.
5.4 False complaint: False accusation and misleading information might be subject to
disciplinary action of appropriate degree according to policy.
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6. Checklists for Code of Conduct:
6.1. For all employees:
i. I have full knowledge of the Code of Conduct and other relevant internal documents (HR
policy, personnel regulations etc.). I understand their content and their implications.
ii. I shall adhere to them and comply with these principles and rules.
iii. I shall adopt a pro‐active behavior. I may have to modify some of my habits in order to do
so.
iv. I shall provide my feedback, positive or otherwise, in any situation.
v. I know how to react, and whom to contact at my office and at the head office if I suspect
a violation of conduct, receive a hint from a colleague having a problem, or feel victimized
myself.
6.2 For Department Head:
i. Each of my employees has a copy of the CoC and of the relevant key documents (personnel
policy, personnel regulations).
ii. I shall regularly check that the content of our policies is understood and well received.
iii. I am responsible for implementing them in my project/office.
iv. I shall constantly try to increase awareness on specific issues among my employees in
meetings, training programs, etc.
v. I shall encourage people to provide feedback.
vi. I shall regularly take time to investigate how people feel.
vii. If needed, I shall ask for support from the head office or from an external source. I know
who to contact regarding specific issues.
6.3 For Head of Human Resources:
i. I shall encourage people to give me their feedback.
ii.
iii.
I shall regularly take time to investigate how people feel.
As soon as I receive a query or a complaint, I shall make sure to acknowledge its origin and
inform the relevant person about the next steps.
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iv. If needed, I shall ask for support from senior management. I know who to contact regarding
specific issues.
6.4 For Management:
i. When travelling, I shall enquire about the CoC and take time to inquire about any HR
concerns.
ii.
iii.
I shall regularly check that the CoC is being enforced and, if needed, updated.
When rules/procedures/policies/regulations are modified, I shall inform all parties
concerned.
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