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Code of conduct

Traverse Health strives to foster innovation and achieve long-term success while prioritizing economic, social, and environmental sustainability for the benefit of Traverse Health and its stakeholders. We believe that creating lasting innovation is our greatest contribution to society. As Traverse Health continues to expand and develop, our unwavering commitment to Our Mission, which is to advance healthcare and promote health equity through real-world evidence data from underrepresented regions and patient populations, remains intact. Our Mission and Values serve as the foundation of our culture and guide our actions as individuals and as a company. Each of us bears the responsibility of making decisions that impact our reputation, relationships with one another, customers, business partners, and communities. Upholding ethical conduct, integrity, and transparency in our business practices is crucial to maintaining our culture and safeguarding our brand.

This Code is not only intended for Traverse Health employees, but temporary employees and persons working for Traverse Health on a contract basis must also comply with the Code of Conduct. Companies and persons working for or on behalf of Traverse Health as a result of outsourcing services, processes or other business activities are also expected to act in line with the Code of Conduct when acting for or on behalf of Traverse Health

Confidential and personal data

At the core of our organization's values and objectives is the goal of safeguarding sensitive health data, aligning with the broader Environmental, Social, and Governance (ESG) objective of Protecting Confidential and Personal Data.
Within our policy document, we have dedicated a section specifically addressing our approach to working with sensitive data. This section outlines our commitment to maintaining the highest standards of data security, privacy, and compliance. We understand the sensitive nature of health information and the trust that patients place in us when sharing their data, and we take this responsibility with the utmost seriousness.

To achieve our goal of protecting confidential and personal data, we have implemented stringent measures throughout our organization. These measures include:
Data Encryption: We utilize robust encryption technologies to safeguard patient data both at rest and in transit. This ensures that any information exchanged within our systems remains secure and protected from unauthorized access.
Access Controls: We enforce strict access controls, limiting the availability of patient data only to authorized personnel who require access to perform their specific roles. This ensures that sensitive information is accessible only to those with a legitimate need and that it remains confidential.
Data Handling and Storage: Our organization follows industry best practices for data handling and storage. We employ secure data storage systems and conduct routine audits to identify and address any vulnerabilities promptly.
Compliance with Regulations: We adhere to all relevant data protection laws, regulations, and guidelines. This includes compliance with the General Data Protection Regulation (GDPR) and any other applicable regional or industry-specific requirements.
Employee Training and Awareness: We prioritize comprehensive training programs to educate our employees on the importance of data protection, privacy, and confidentiality.

Handling Infringements

At our organization, we place a high value on ethical conduct and the integrity of our business operations. We recognize that failure to report an infringement not only compromises our code of conduct but also undermines the trust and confidence we strive to build with our stakeholders.

Any employee who becomes aware of a potential infringement, whether it involves unethical behavior, legal violations, or any other breach of our code of conduct, is obligated to promptly report it through the designated channels. We encourage an environment of transparency and accountability, where individuals feel safe and empowered to raise concerns without fear of retaliation.

Upon receiving a report of an infringement, our organization is committed to conducting a thorough and impartial investigation. We will take appropriate action to address the issue, including implementing corrective measures and disciplinary actions if necessary. Confidentiality will be maintained to the extent possible, while ensuring that the investigation proceeds effectively and fairly.

We emphasize that failure to report an infringement, either through intentional concealment or negligence, is considered a breach of our code of conduct. It undermines the trust we place in each other and hampers our ability to maintain a culture of integrity. Therefore, it is incumbent upon every employee to fulfill their duty to promptly report any infringements they become aware of.

Money Laundering Provision

Our organization is committed to preventing money laundering and combating the illegal flow of funds through our business activities. Money laundering poses significant risks to society, undermining the integrity of financial systems and facilitating criminal activities. As responsible corporate citizens, we are dedicated to upholding the highest standards of anti-money laundering practices.

We strictly adhere to all applicable laws and regulations related to anti-money laundering efforts. Our employees are expected to be vigilant and proactive in identifying and reporting any suspicious activities or transactions that may potentially involve money laundering.

Our organization maintains a zero-tolerance approach to money laundering and will take immediate action to investigate and address any suspected instances of such activity.

By incorporating this money laundering provision into our code of conduct, we affirm our dedication to maintaining the highest ethical standards and contributing to the global fight against financial crime. It is our collective responsibility to be proactive in identifying and preventing money laundering, ensuring that our business operations remain free from any association with illicit financial activities.

Personal Proactive Approach

At our organization, we believe that upholding a personal proactive approach is instrumental in maintaining a culture of integrity, responsibility, and ethical conduct. Each individual within our organization has a crucial role to play in fostering an environment that promotes accountability and encourages the highest standards of business behavior.

We encourage all employees to take personal ownership of their actions and decisions, demonstrating a proactive mindset in their day-to-day work. This means going beyond mere compliance with policies and regulations and actively seeking opportunities to make positive contributions, both within the organization and in the broader community.

A personal proactive approach entails:
Ethical Decision-Making: We expect our employees to make decisions based on sound ethical principles, considering the impact of their actions on various stakeholders. This involves seeking guidance when faced with ethical dilemmas, questioning the status quo, and choosing the course of action that aligns with our values and the best interests of all parties involved.
Continuous Learning and Development: We encourage employees to engage in ongoing learning and development initiatives to enhance their professional skills and knowledge. By staying abreast of industry trends and best practices, individuals can proactively contribute to the growth and success of our organization.
Initiative and Innovation: Taking initiative means actively seeking opportunities to improve processes, increase efficiency, and drive innovation. We value employees who go above and beyond their assigned tasks, seeking ways to add value and contribute to the organization's overall goals.
Open Communication: We foster an environment that encourages open and transparent communication. Employees are encouraged to actively voice their ideas, concerns, and suggestions, promoting a culture of collaboration and continuous improvement.
Responsible Resource Management: Each employee has a responsibility to manage resources effectively and responsibly. This includes utilizing company assets efficiently, minimizing waste, and promoting sustainable practices that contribute to the long-term well-being of our organization and the environment.
Respect and Inclusion: We promote a culture of respect, valuing diversity and fostering inclusion. Employees are expected to treat their colleagues, clients, and stakeholders with dignity, fairness, and professionalism, creating an inclusive and harmonious work environment.

By embracing a personal proactive approach, we empower individuals to make meaningful contributions and shape the ethical fabric of our organization. We recognize that every employee's actions have a collective impact on our success, reputation, and ability to make a positive difference in the world. Together, let us embrace this proactive mindset and strive for excellence in all that we do.

Anti-Bribery Clause

Our organization maintains a zero-tolerance policy towards bribery and corruption in any form. We are committed to conducting our business with the highest ethical standards and integrity, fostering fair and transparent practices in all our interactions.

Employees, contractors, and representatives of our organization are strictly prohibited from offering, giving, soliciting, or accepting bribes or any improper advantage. This prohibition extends to all business activities, regardless of the location or parties involved. We uphold this commitment not only within our organization but also in our relationships with clients, suppliers, business partners, government entities, and other stakeholders.

We define bribery as the offering, giving, promising, or accepting of any form of financial or non-financial benefit, including but not limited to cash, gifts, favors, kickbacks, or hospitality, with the intent to improperly influence a person's actions or decisions in the course of business.

In line with this commitment, we adhere to the following principles:
Compliance with Applicable Laws: We comply with all relevant anti-bribery and anti-corruption laws and any other applicable national or international legislation. We also respect any additional local laws or regulations in the jurisdictions where we operate.
Due Diligence: We exercise due diligence in selecting and engaging business partners, suppliers, agents, and other intermediaries. We ensure that they share our commitment to ethical business practices and do not engage in bribery or corruption.
Gifts, Entertainment, and Hospitality: We acknowledge that the exchange of gifts, entertainment, and hospitality can be a legitimate part of business relationships. However, such exchanges must be reasonable, transparent, and in compliance with applicable laws and our internal policies. Employees must exercise caution to avoid situations that may create a perception of impropriety or compromise their independence and judgment.
Reporting and Whistleblowing: We encourage all employees to report any suspected or observed instances of bribery, corruption, or improper conduct through our designated reporting channels. We ensure that all reports will be treated confidentially, and there will be no retaliation against those who report in good faith.
Consequences of Non-Compliance: Any employee found to have breached this anti-bribery policy will be subject to disciplinary action, which may include termination of employment, legal proceedings, and other appropriate measures. We will also cooperate fully with law enforcement agencies and regulatory authorities in the investigation and prosecution of bribery and corruption cases.

By incorporating this anti-bribery clause into our business ethics code, we reinforce our commitment to fair competition, ethical conduct, and the prevention of corruption. Together, we work towards maintaining the trust and confidence of our stakeholders while upholding the highest standards of integrity in all aspects of our business operations.

Respect and Healthy Environment

Traverse Health prioritizes the establishment of a work environment that promotes health, safety, and productivity, upholding principles of respect, dignity, and non-discrimination. We are fully committed to complying with all relevant local laws and regulations that prohibit discrimination and harassment. At Traverse Health, we have a zero-tolerance policy towards any form of discrimination, including but not limited to sexual harassment, bullying, or any conduct that contributes to a hostile work environment. We are dedicated to abiding by both external and internal guidelines, including health and safety laws, regulations, and policies, to ensure the well-being and safety of our employees.

Additionally, we place a strong emphasis on fair treatment of employees, guided by the following principles:
Non-Discrimination: We are committed to maintaining a workplace free from discrimination based on race, color, religion, gender, sexual orientation, national origin, disability, or any other protected characteristic. All employees shall be treated with fairness, respect, and dignity, fostering an inclusive and diverse work environment.
Equal Opportunities: We provide equal opportunities for all employees, ensuring that recruitment, hiring, promotions, training, and other employment decisions are based on merit, skills, qualifications, and performance. There shall be no unfair advantage or bias in any employment-related practices.
Harassment and Bullying: We strictly prohibit any form of harassment or bullying, including but not limited to verbal, physical, or psychological abuse. We promote a safe and respectful workplace, where individuals are encouraged to report any instances of misconduct without fear of retaliation.
Work-Life Balance: We recognize the importance of work-life balance and strive to provide a supportive environment that allows employees to fulfill their personal and professional commitments. We aim to offer flexible work arrangements, reasonable working hours, and appropriate leave policies to promote the well-being of our employees.
Health and Safety: We prioritize the health and safety of our employees by providing a safe and healthy work environment. We comply with all applicable laws and regulations related to occupational health and safety, take necessary precautions, and provide adequate training to prevent accidents, injuries, and occupational hazards.
Compensation and Benefits: We ensure fair and competitive compensation and benefits packages that align with industry standards and recognize the contributions of our employees. Remuneration is based on factors such as job responsibilities, performance, and market value, aiming to provide a living wage and support the financial well-being of our workforce

Policy authorised by
Director CEO Alex Loleit

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