Code of Conduct

ROC Clinic's Code of Conduct is a guide that compiles honest, respectful and integral behavior guidelines addressed to both ROC Clinic's professional team and its stakeholders. It is the articulation of a set of principles and values in business behavior and a written reflection of a public commitment to them.

This Code of Conduct is addressed to persons, entities and stakeholders as direct addressees, as well as to persons or entities that must be or may be aware of it:

Individuals who provide services to ROC Clinic as administrators, managers, employees and collaborators.
Representatives, agents, agents and mediators acting in the interest of or on behalf of ROC Clinic.
Patients, patients' relatives, suppliers, consultants and other persons or entities that are related to ROC Clinic for professional, health, commercial or business reasons. These persons, in addition to being informed by ROC Clinic, must accept that their relations with the clinic, the conduct of the company and of the individuals to whom this Code is addressed, are governed by the provisions of this Code.

Any person who does not have a direct relationship with ROC Clinic but who has an interest in knowing the principles and values that govern its business conduct or in bringing to the clinic's attention a violation of the rules contained in this Code.

It is expected that those to whom this Code of Conduct is addressed and who are aware of it will collaborate in the dissemination and effective application of it and avoid its violation. Likewise, managers are expected to set an example to the rest of the organization in its knowledge, dissemination and compliance.

Principle and values of business conduct

The principles and values of business conduct to which ROC Clinic is committed at the highest level are:

Compliance with the law.
Integrity and objectivity in business performance.
Respect for people.
Protection of health and physical integrity.
Environmental protection.
Efficient management.
Use and protection of information.
Quality and safety.

1. Compliance with the Law.

ROC Clinic's first commitment to business conduct is to comply with the law and to collaborate with the justice system in the event of possible violations of actions constituting a crime and from which the company may derive direct criminal liability, in accordance with the provisions of Article 31 bis of the Spanish Criminal Code in force or any other provision in this regard that may replace and/or complement it in the future.

When it is legally permitted in the course of ROC Clinic's business to choose between the law of two or more countries, the clinic may choose the law it deems most appropriate.

Relations with authorities and public representatives.

ROC Clinic will act in a respectful manner and in accordance with the applicable law to promote and defend its legitimate interests in its relations with authorities and public representatives in Spain and other countries.

The addressees of this Code of Conduct shall cooperate with the authorities and public representatives when exercising the functions that legally correspond to them.

Money laundering.

The recipients of this Code of Conduct shall refrain from promoting, facilitating, participating in or concealing any type of money laundering operation and shall, in any case, report any money laundering operation of which they become aware to their immediate superior or to the Secretariat of the Code of Conduct Monitoring Committee.

2. Integrity and objectivity in business performance.

The actions of the addressees of the Code of Conduct must always seek the most convenient alternative to the company's interests that are permitted by the applicable law and by this Code of Conduct.

Rejection of arbitrariness.

You may not act arbitrarily or put your own interests or those of third parties first, either to your advantage or to your detriment, by taking a decision other than the one that is objectively more convenient to the interests of ROC Clinic.

Conflict of interest.

When personal interests interfere with an employee's ability to use his or her judgment objectively or to perform his or her job honestly and transparently. Examples may include:

Deciding or recommending the award of a ROC Clinic contract to a company in which a relative of the decision-maker was employed.
Making a business decision that may benefit a friend or relative of the decision-maker, either because the decision-maker benefits directly from the decision-maker or because the company in which the decision-maker works will benefit from the decision.
Work for clients, suppliers or subcontractors of ROC Clinic, without prejudice to the responsibilities that may be incurred in terms of incompatibilities in the service of the public sector.
Own a business that operates within the ROC Clinic markets.

When a recipient of this Code of Conduct finds himself/herself in a situation of conflict of interest, he/she must inform his/her superiors and not make any decision on the matter. If his or her superiors instruct him or her to proceed once the potential conflict of interest has been considered, then the recipient may make the decision that is objectively in the best interest of ROC Clinic.

When allowing an addressee of this Code in a situation of conflict of interest to make the decision in which the conflict exists, his or her superiors shall take into account not only the integrity and objectivity of the person making the decision, but also whether the company's image of objectivity may be affected. When the addressee of the Code of Conduct who is in a situation of conflict of interest is part of a group of people collectively responsible for making the decision (such as committees or working groups), he/she shall inform the rest of the people responsible for making the decision when it is collective and shall abstain from participating in any voting.

ROC Clinic employees may not work for competitors, patients, clients, customers, distributors or suppliers of the company, or engage in personal business that may be detrimental to the company without authorization. Any outside activity carried out by an employee must be strictly separate from the work performed by ROC Clinic and must not affect the performance of its activity and must be subject to the authorization regime provided for in the Public Sector Incompatibilities Law. If an employee initiates an activity that could lead to a conflict of interest, he/she must inform his/her superior or the director of the organization, who will decide on the matter or take it to a higher level if he/she deems it appropriate.

Favoritism.

ROC Clinic is committed to avoid favoritism or nepotism in decisions related to hiring, internal promotion or training. This means that no aspects other than the candidate's training, experience and personal worth, such as kinship or friendship with a ROC Clinic employee, will be taken into account when making decisions regarding these activities.

Gifts and hospitality.

In dealings with third parties and companies, recipients of this Code of Conduct shall never give gifts or entertainment whose economic value exceeds what may be considered reasonable and moderate in view of the circumstances of the matter and the place concerned. Where the rules of conduct applicable to third parties or companies prohibit or limit gifts and entertainment below the threshold of reasonableness and moderation, recipients of this Code of Conduct shall refrain from making any invitation or offering any gift in violation of the rules of conduct applicable to potential recipients.

Likewise, the recipients of this Code will refuse any gift or invitation whose economic value exceeds what may be considered reasonable and moderate given the circumstances of the matter and the place in question. The refusal will always be made politely, explaining that it is in accordance with ROC Clinic's Code of Business Conduct.

In those exceptional cases in which, in accordance with the business practices of a foreign country, it is necessary to accept gifts that exceed the value considered moderate and reasonable in Spain, the gift will be accepted on behalf of the company, which will be the sole owner.

Insider information.

The recipients of this Code of Conduct will never use the information they learn as a result of their relations with the ROC Clinic to obtain a personal economic advantage, nor will it be provided to third parties so that they can obtain the same type of advantage.

Respect for free competition.

ROC Clinic is committed to free competition. Consequently, whenever ROC Clinic competes with one or more competitors to develop a commercial, entrepreneurial or business operation, the addressees of this Code of Conduct will refrain from any anti-competitive practice in order to favor ROC Clinic's interests. The following are considered anti-competitive practices:

Unlawfully obtaining information about the competitor's product or offer.
The agreement with one or more competitors to fix prices and other determining elements of the offer to which the bid is submitted.
The dissemination of false or misrepresented information that is detrimental to one or more competitors.

Fulfillment of contracts.

Contracts drawn up by ROC Clinic must be effective and in compliance with all agreements. The addressees of this Code of Conduct may not unreasonably impede or hinder the fulfillment of the company's contracts.

Honest negotiation.

ROC Clinic rejects any type of corrupt practice, especially bribery. The recipients of the Code of Conduct shall refrain from promoting, facilitating, participating in or covering up any type of corrupt practice.

In conducting its international business, the ROC Clinic will be guided by the recommendations and guidelines issued by business associations, the Code of Conduct Monitoring Committee and the Organization for Economic Cooperation and Development (OECD).

3. Respect for people.

Respect for people is a fundamental principle.

Relationship with patients.

ROC Clinic is committed to providing the best service and care to its patients throughout the entire relationship. This involves:

Treat patients without discrimination, with respect, honesty and kindness.
Provide patients with information on health care services or any other request in a clear, transparent and understandable manner.
To offer a constant and responsible service based on teamwork, with the involvement of all employees, regardless of their position, occupation or department to which they belong.

Promote the improvement of care, showing interest, helping them with their problems to improve their satisfaction with the treatment received.
Design and provide comfortable services in accessible and safe environments, to the extent possible.

Respectful treatment.

The recipients of this Code of Conduct shall treat all natural persons with whom they come into contact with due respect.

Violence and aggressive behaviors.

ROC Clinic prohibits recipients of this Code from any violent conduct or aggressive behavior, either physically or verbally.

Equality and non-discrimination.

ROC Clinic guarantees to all, and especially to its employees, equal and non-discriminatory treatment regardless of race, color, religion, sex, sexual orientation, nationality, age, pregnancy status, degree of disability and other legally protected circumstances. All addressees of this Code of Conduct shall act accordingly, knowing and favoring such policies.

Harassment.

ROC Clinic prohibits and prosecutes harassing conduct in the work environment.

Reconciliation of personal, family and work life.

The company is committed to facilitating the reconciliation of the personal, family and work life of its employees.

Respect for Human Rights.

ROC Clinic is committed to respecting the Human Rights of all individuals, especially in their relationship with the company's personnel, such as the right of association (freedom of association and the right to collective bargaining), the rights of children and young people (elimination of child exploitation and forced labor) or the right to fair and satisfactory employment conditions.

4. Protection of health and physical integrity.

Risk Prevention.

ROC Clinic attaches the utmost importance to the protection of the physical integrity and health of people and the prevention of any type of risk to them in the workplace. The company will comply with the applicable laws and will implement a comprehensive policy of occupational risk prevention appropriate to the activity in the workplace.

The recipients of the Code of Conduct must report, through their superiors or those responsible for occupational health, the existence of any situation of danger or presumed violation of the rules on this matter.

Protected drugs and substances.

ROC Clinic is committed to a work environment free of drugs and the influence of other prohibited substances that can alter people's behavior. The recipients of this code of conduct shall refrain from performing their work under the influence of drugs or other prohibited substances, as well as the abusive consumption of alcohol. Such consumption is prohibited in the workplace.

5. Environmental protection.

ROC Clinic acts in accordance with environmental protection laws and regulations. The addressees of this Code must ensure compliance with it and inform their superiors or those responsible for environmental management of all risks and violations of these procedures of which they are aware.

6. Efficient management.

Obtaining margin.

The purpose of ROC Clinic's business action is to obtain economic margin in the exercise of its activity within the limits established by laws, contracts and this Code of Conduct. All those to whom the Code is addressed shall endeavor to obtain the margin within these limits.

Adequate resource management.

In order to facilitate the achievement of business margin, the recipients of this Code of Conduct shall at all times endeavor to manage the company's resources in the most efficient manner, avoiding superfluous expenses.

Use of company resources for personal purposes.

Except for those cases in which common logic, legislation or company rules authorize the use of company resources for personal purposes, the recipients of this Code of Conduct shall refrain from using any of the company's resources as their own.

7. Use and Protection of Information.

Protection of confidential information.

ROC Clinic has access to information about its patients, users and providers that is provided under a commitment of confidentiality. The company is committed not to disclose and to protect this confidential information.

Protection of personal data.

ROC Clinic takes special care to protect the personal data of the persons to whom it has access in the course of its activity, always complying with the applicable laws and regulations.

Classified information.

Patients and users of ROC Clinic may entrust information that the laws of different countries protect as classified information. This information must be subject to special treatment aimed at ensuring its protection, which ROC Clinic assumes as a priority in the treatment of its patients and users.

Commitment to transparency.

Provided that it does not affect classified or confidential information, ROC Clinic is committed to the transparency of its performance, disclosing to the general public the information established by law and that which is reasonable to disclose about the company's activity and business.

8. Quality and safety.

The principles of quality and safety are part of the organizational culture of ROC Clinic which, establishing safety and quality as a priority, aims to achieve maximum customer satisfaction, with proper compliance with the requirements established in the contracts. ROC Clinic will carry out patient and user satisfaction evaluations, analyzing the results and implementing improvement measures.

Dissemination and application of the Code of Conduct

Training actions.

The Code of Conduct is available to all stakeholders on the corporate website (www.rocclinic.com) and will be sent by e-mail to those stakeholders deemed appropriate.

Likewise, ROC Clinic will carry out information and awareness actions so that its employees have sufficient knowledge of the content of this Code of Conduct. In addition to general training and information, ROC Clinic will provide specialized training to those groups of its managers or employees who, due to the tasks they perform, must have a more precise and detailed knowledge of the rules of conduct applicable to their area.

Support and advice.

The recipients of this Code of Conduct will have the support and advice of their managers and superiors to communicate their doubts about it.