The Anti-Bribery and Corruption Procedure

The Anti-Bribery and Corruption Procedure applies to all employees and all persons who provide services for or on behalf of the hospital and contains guidelines on how to deal with inappropriate requests, bribes and other forms of corruption and problems that may arise in the course of work. A body responsible for overseeing the procedure’s scope and implementation has been created - an Irregularities Committee composed of representatives from the following departments: Internal Audit, Legal Department and Enterprise Risk Management.

The rules contained in the document are implemented based on an anti-corruption plan made up of several components.

First of all, there are anti-corruption and anti-bribery management authorities (the Board of Directors which has collective responsibility for setting the anti-corruption framework and monitoring its implementation, and the Irregularities Committee which is responsible for the overall development, implementation, coordination and reporting of measures).

Then obligations for employeeshave been introduced and underpinned by sanctions for failure to comply, such as dismissal, civil and criminal action, fines, imprisonment.

Last but not least expectations of third parties and their representatives have been outlined.They cover several aspects including: commitment to share values and ethical standards; risk-based due diligence process to assess integrity and ability to comply with the Anti-Bribery and Corruption Procedure; providing information and documentation to assess compliance with respective requirements; commitment to report any case of corruption or suspicion of irregularities with guaranteed anonymity.

The document further sets out general requirements to prevent bribery, corruption and improper payments of any kindand provides clear definitions of the different forms of corruption in a separate appendix. It is expressly stated that employees and third parties may not directly or indirectly make, promise, approve, authorize or offer to give to anyone - or accept or solicit from anyone - anything of value (including but not limited to cash payments) if the purpose or effect is to improperly induce the recipient to take (or to refrain from taking) action that would bestow a commercial benefit. Special attention is given to the question of unfavorable transactions – all facilitation payments are forbidden. Charitable and political contributions are allowed as far as they comply with the relevant provisions of the national legislation.

The Procedure includes control measures to ensure its implementation along several lines: 1) including anti-bribery and anti-corruption clauses in contracts with third parties; 2) annual review of the Procedure: the Anti Bribery and Corruption Procedure is to be reviewed on an annual basis or as and when necessary; 3) annual corruption-related risk assessment by all involved in cooperation with the Irregularities Committee.

Another important aspect of the procedure is the requirement to provide mandatory training and awareness-raising to all hospital staff. The Human Resources Department keeps records of all training certificates. Third parties and their representatives must also be made aware of the anti-corruption rules and must undertake a commitment in written form to follow them. There is also an alternative way to ensure awareness of the anti-corruption measures – by submitting declarations committing to follow the Anti-Bribery and Corruption Procedure as part of the tender procedure.

Furthermore, the document contains obligations to report on the implementation of anti-corruption policies and on their transparency. To this end the Irregularities Committee is authorized to request information from the respective bodies.

The procedure is accompanied by a number of appendixeswhich provide detailed information (laws and regulations; types of corruption, definitions and manifestations) and specimen documents (anti-bribery and anti-corruption contract clauses; confidentiality declarations for suppliers/service providers).

Source: https://acibademcityclinic.bg/docs/default-source/privacy-files-gdpr/bg-antibriberycorruptionpolicy_2021.pdf?Status=Master&sfvrsn=78251198_6