Purpose

Mawuli Diagnostic & Treatment Centre (MDTC) needs to possess a tradition of ethical standards in the provision of health care services as well as in the management of its business affairs. The code of conduct supplements the mission, vision, and values of MDTC and applies to all who provide services under the auspices of MDTC. Our code of conduct provides guidance to all who carry out daily activities within appropriate ethical and legal standards. It provides a standard of conduct to protect and promote integrity and to enhance MDTC’s ability to achieve its mission and compliance goals.

Who should read?

The Code of Conduct must govern the actions of MDTC. It is to be read by employees and service providers who need to become familiar with the job-specific legal requirements and recognise circumstances that may raise issues. They are required to sign the Acknowledgement Form confirming that they have received and read the Code of Conduct and are prepared to adhere to its terms.

Code of Conduct
It has seven principles:
1.    Confidentiality
2.    Business Ethics
3.    Legal and Regulatory Compliance
4.    Professional Conduct
5.    Conflicts of Interest
6.    Appropriate use of resources
7.    Responsibility
1. Confidentiality

Employees and those affiliated with Mawuli Diagnostic & Treatment Centre (MDTC) are obliged to maintain the confidentiality of patients, personnel, and other proprietary information, as well as with those who enter into business or professional relationships with MDTC. As such, employees are entrusted with a wide spectrum of confidential information, which remains the sole property of MDTC. Sharing of confidential information with other employees or others outside the organisation is strictly forbidden, unless the person requesting the information has a legitimate reason to know it for MDTC business-related purposes.

Media Relations

All requests from reporters or the general public for information should be referred to Public Relations.

2. Business Ethics

MDTC is committed to the highest standard of business ethics and integrity, and requires honesty when representing MDTC. MDTC is committed to ensuring that its billing and reimbursement practices comply with applicable laws, regulations, guidelines, and policies of Ghana and all other countries where it operates, and that all billing is accurate.

Book & Accounting

MDTC payment and other transactions are to be properly authorized by management, and are to be accurately and completely recorded in accordance with generally accepted accounting principles and established corporate policies. This serves as a basis for managing the business and is important to meeting obligations to patients, suppliers, and others. MDTC’s high standard of accuracy and documentation is necessary for tax and financial reporting requirements.

The duty to report accurate and truthful information also applies to our internal dealings. All work-time and expenses recorded are to be reported accurately and honestly.

Kick-Backs/Bribes

MDTC prohibits its employees and other service providers from offering, paying, asking for, or accepting any money or other benefit in exchange for patient referrals, purchases, leases, or orders. All contracts and other referral sources must follow all applicable laws.

Antitrust

MDTC engages in activities and antitrust laws that are subject to the Republic of Ghana and the subsequent countries in which it operates. Generally, those laws prohibit competitors from entering into agreements to fix prices or to reduce price competition. MDTC employees should not provide information about MDTC to business competitors. In addition, employees are to refrain from engaging in unfair practices that might restrict competition.

Billing

Billing must comply with all applicable laws, rules, and policies. Employees who handle patient charges, claims, and records must accurately document and report services and supplies. MDTC prohibits its employees or agents from knowingly presenting, or causing to be presented, claims for payment or approval that are false, fictitious, or fraudulent.

Fraud

MDTC policies and various Republic of Ghana and the subsequent countries in which it operates laws prohibit fraudulent claim activity. The laws of Ghana prohibit conduct such as knowingly submitting a false or fraudulent claim, or using or making a false statement to get a false or fraudulent claim paid. Other laws governing medical program integrity also look for ways to reduce fraud and abuse. MDTC and its employees and other service providers can be prosecuted for filing inaccurate claims for reimbursement and can be subject to civil fines, criminal penalties or both.

MDTC expects employees to report known or suspected activity of this type to the Corporate Compliance Office or the Management Committee. Employees who lawfully report false claims or other fraudulent conduct or who otherwise assist in an investigation, action or testimonies are protected from retaliation to the furthest extent possible under the laws of Ghana and the subsequent countries in which it operates.

Performing routine audits or reviews and monitoring, along with internal controls, helps MDTC prevent and detect fraud, waste and abuse.

Gift

Employees are prohibited from soliciting tips, personal gratuities, or gifts from patients or vendors.

Intellectual Property

MDTC is committed to adhering to all applicable intellectual property laws. Additionally, MDTC will respect the intellectual property and copyright laws regarding books, trade journals, magazines, and other applicable resources. All software used in connection with MDTC must be properly licensed and used in accordance with that license.

Marketing

Marketing and advertising activities may be utilized for the following purposes: to educate the public, to provide information to the community, to increase awareness of our services, and to recruit employees. Marketing materials and media announcements must be presented in a truthful, fully informative, and non-deceptive manner.

Research

MDTC is committed to the following ethical standards in full compliance with the laws and regulations in any research, investigations, and clinical trials conducted. MDTC is dedicated to integrity in disseminating appropriate and valid scientific results in accordance with applicable regulations and guidelines. It is MDTC’s priority to protect the rights of its subjects. As in all financial accounting and record-keeping, MDTC’s policy is to submit accurate and complete costs related to research grants.

Travel

Travel and entertainment expenses of an employee must be consistent with his/her job responsibility and the needs and resources of MDTC. Employees are encouraged to participate in and attend educational workshops, seminars, and training sessions.

3. Legal & Regulatory

All activities by or on behalf of MDTC are to comply with all laws and regulations of the Republic of Ghana and the subsequent countries in which it operates.

Health & Safety

MDTC employees and other healthcare providers are expected to comply with laws designed to improve workplace safety, such as properly controlling and monitoring dangerous materials and maintaining safe equipment. This includes adhering to protocols for the handling and disposal of hazardous substances, ensuring that all equipment is regularly inspected and maintained, and following safety guidelines to prevent accidents and injuries. By doing so, MDTC aims to create a safe and healthy working environment for all its employees and to protect the well-being of patients and the community.

The Environment

Employees are to dispose of all waste and other materials and store all chemicals and substances in accordance with applicable laws and regulations. It is important to file all necessary environmental reports accurately and promptly and to cooperate fully with all governmental authorities in the event of an environmental incident. This ensures that MDTC maintains a high standard of environmental responsibility and compliance, safeguarding both the community and the environment.

Harassments

Mawuli Diagnostic & Treatment Centre does not discriminate with regards to race, religion, gender, sexual orientation, pregnancy, marital status, age, nationality, ethnicity, ancestry, disability, or status as a disabled or military veteran. MDTC also does not tolerate harassment.

Controlled Substances

Many controlled drugs, controlled substances, and other medical supplies are governed and monitored by specific regulatory organizations and are to be administered by physician's orders only. Prescription and controlled medications and supplies are to be handled properly and only by authorized individuals to minimize risk to MDTC and to patients. This ensures that all medications are used safely and effectively, reducing the potential for misuse or errors. Compliance with these regulations is crucial for maintaining the integrity and trustworthiness of the healthcare services provided by MDTC.

Screening

MDTC will not knowingly employ or contract with individuals or entities that have been listed as debarred or excluded or otherwise ineligible for participation in national healthcare programs. As a condition of employment, employees are required to notify Human Resources immediately if they currently are, or to the best of their knowledge, will be in the future, listed by the Armed Forces of the nation where MDTC operates. This ensures that MDTC maintains compliance with national regulations and upholds the integrity and safety of its healthcare services.

4. Conducts

MDTC also has a code of conduct that addresses specific healthcare professional responsibilities to patients and to each other.

5. Conflicts of Interest
Employees and other service providers owe a duty of complete loyalty to MDTC and may not use their position to profit personally at the expense of the organization, financially or otherwise. Potential conflicts of interest should be directed to the Legal Office for evaluation.
Family & Work
Employment of immediate relatives (including a spouse, parent, stepparent, children, stepchildren, sister, brother, son-in-law, daughter-in-law, sister-in-law, mother-in-law, and father-in-law) is not permitted where an employee has or would have direct or indirect administrative, supervisory, or decision-making authority over the related person.
Insider Trading
No employee of MDTC shall use non-public information acquired through employment at MDTC to trade in the securities of any company, or buy or sell any property or assets.
Outside Activities

MDTC employees and other service providers who hold positions of trust and stewardship should refrain from directly or indirectly performing duties, incurring obligations, or engaging in business or professional relationships where there would appear to be a conflict of interest. No outside activity may interfere with your job performance.

Political Activity

MDTC does not participate in, or intervene in, any political campaign on behalf of, or in opposition to, any candidate for political office. While MDTC supports employee participation in the political process, employees are not permitted to use their position in the organisation to try to influence the personal decisions of others to contribute to, or to otherwise support, political parties or candidates, except as lawfully permitted through political action committees. MDTC may choose to support specific issues with the approval of the Legal Office.

Informations

MDTC closely controls the dissemination of proprietary information. Except as specifically authorised by management pursuant to established policy and procedure, an employee should not disclose to any outside party any non-public business, whether financial, personnel, commercial or technological information, plans or data acquired during employment at MDTC.

6. Use of Resources

Those affiliated with MDTC have a duty to preserve and protect the assets of the system and to ensure their efficient use. Theft, carelessness, and waste have a direct impact on the organisation’s success. As a rule, MDTC prohibits the personal use of its property. Employees may not use equipment, supplies, materials, or services for non-work-related purposes. Employees have no expectation of personal privacy in connection with personal or work use of MDTC’s electronic resources.

7. Responsibility

Violations of the responsibilities outlined in this Code of Conduct and MDTC policies and procedures can lead to disciplinary action, up to and including dismissal. Conduct that violates the law also may result in civil and criminal penalties ranging from fines to imprisonment.

Reporting

Employees and those affiliated with MDTC have a responsibility to report any suspected or actual violation of the Code of Conduct or other policy irregularities to a supervisor, the Corporate Compliance Office, or the Office of General Counsel. For those who wish to remain anonymous, the report may be submitted through one of the MDTC Compliance Reporting Lines. There would not be any negative consequences or retaliation for good faith reporting of possible misconduct.