Purpose
Wonder International Hospitals (WIH) needs to possess a tradition of ethical standards in the provision of health care services as well as in management of its business affairs. The code of conduct supplements the mission, vision and values of WIH and applies to all who provide services under the auspices of WIH. Our code of conduct adopted provides guidance to all who carry out daily activities within appropriate ethical and legal standards. It provides standard of conduct to protect and promote integrity and to enhance WIH’s ability to achieve its mission and compliance goals.
Who should read?
The Code of Conduct must govern the actions of WIH. It is to be read by employees and service providers who need to become familiar with the job specific legal requirements and recognize 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 Wonder International Hospitals (WIH) are obliged to maintain the confidentiality of parents, personnel and other proprietary information, as well as with those who enter into business or professional relationship with WIH. As such employees are entrusted with a wide spectrum of confidential information, which remains the sole property of WIH. Sharing of confidential information with other employees, or others outside the organization is strictly forbidden, unless the person requesting the information has a legitimate reason to know it for WIH business-related purposes.

Media Relations
All requests from reporters or the general public for information should be referred to the Public Relations.
2. Business Ethics
WIH is committed to the highest standard of business ethics and integrity, and requires honesty when representing WIH. WIH 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 and Accounting
WIH 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 obligation to patients, suppliers and others. WIH’s high standard of accuracy and documentation is necessary for tax 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
WIH prohibits its employees and other services 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 are to follow all applicable laws.
Antitrust
WIH 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. WIH employees should not provide information about WIH to business competitors. In addition employees are to refrain from engaging in unfair practices that might restrict competition.
Billing
Billing is to comply with all applicable laws, rules and policies. Employees who handle patient charges, claims and records are to accurately document and report services and supplies. WIH prohibits its employees or agents from knowingly presenting, or causing to be presented, claims for payment or approval, which are false, fictitious or fraudulent.
Fraud, and Abuse
WIH 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 false statement to get false or fraudulent claim paid. Other laws governing medical program integrity also look for ways to reduce fraud and abuse. WIH and its employees and other service providers can be prosecuted for filling inaccurate claims for reimbursement and can be subject to civil fines, criminal penalties or both. 

WIH 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, help WIH prevent and detect fraud, waste and abuse.

Gift & Gratuities
Employees are prohibited from soliciting tips and personal gratuities or gifts from patients or vendors.
Intellectual Property
WIH is committed to adhering to all applicable intellectual property laws. Additionally, WIH will respect the intellectual property and copyright laws regarding books, trade journals, magazines and other applicable resources. All software used in connection with WIH must be properly licensed, used in accordance with that license. 
Marketing & Adverts
Marketing and advertising activity 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 are to be presented in a truthful, fully informative and non-deceptive manner.
Research
WIH is committed to the following ethical standard in full compliance with the laws and regulations in any research, investigations and clinical trials conducted. WIH is committed to integrity in disseminating appropriate valid scientific results in accordance with applicable regulations and guidelines. It is WIH’s priority to protect the rights of its subjects. As in all financial accounting and record keeping, WIH’s policy is to submit accurate and complete cost related to research grants.
Travels
Travel and entertainment expenses of an employee must be consistent with his/her job responsibility and the needs and resources of WIH. Employees are encouraged to participate in and attend educational workshops, seminars and training sessions.
3. Legal & Regulatory
All activities by or on behalf of WIH is to comply with all laws and regulations of the Republic of Ghana and the subsequent countries in which it operates.
Health & Safety
WIH 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.
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.
Discrimination
Wonder International Hospitals 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. WIH also does not tolerate harassment.
Regulations
Many controlled drugs, controlled substances, and other medical supplies, are governed and monitored by specific regulatory organizations and are to be administered by physicians orders only. Prescription and controlled medications and supplies are to be handled properly and only by authorized individuals to minimize risk to WIH and to patients.
Screening of Individuals
WIH 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 Resource immediately, if they currently, or to the best of their knowledge, will be in the future, listed by the the Armed Forces of the nation where WIH operates.
4. Professional Conduct
WIH also has a code of conduct that addresses specific healthcare professional responsibility to patient and to each other.
5. Conflicts of Interest
Employees and other service providers owe a duty of complete loyalty to WIH and may not use their position to profit personally at the expense of the organization, financially or otherwise. Potential conflict 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 WIH shall use non-public information acquired through employment at WIH to trade in the securities of any company, or buy or sell any property or assets.
Outside Activities
WIH employees and other service providers who hold position of trust and stewardship should refrain from directly or indirectly performing duties, incurring in obligations or engaging in business or professional relationships where there would appear to be conflict of interest. No outside activity may interfere with your job performance.
Political Activity
WIH does not participate or intervene in any political campaign on behalf of, or in opposition to, any candidate for political office. While WIH supports employee participation in the political process, employees are not permitted to use position in the organization to try to influence the personal decisions of others to contribute, or to otherwise support political parties or candidates, except as lawfully permitted through political action committees. WIH may choose to support specific issues with approval of the Legal Office.
Proprietary Information

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

6. Use of Resources
Those affiliated with WIH 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 organization’s success. As a rule WIH 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 WIH’s electronic resources.
7. Responsibility
Violations of the responsibilities outlined in this Code of Conduct and WIH policies and procedures can lead to the 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 WIH 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 WIH Compliance Reporting Lines. There would not be any negative consequences or retaliation for good faith reporting of possible misconduct.