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      07. Healthsafe Ethics & Disciplinary Policy



      ETHICS & DISCIPLINARY POLICY




      Document Identification 

      HSNZ/POL/07

      Document Name

      Ethics & Disciplinary Policy

      Master Copy

      CISO

      Version Number

      1.3

      Date Of Release 

      15 Aug 2023

      Prepared By

      Eparama Tuibenau

      CISO

      Approved by

      Kevin McAfee

      Managing Director


       

       


      VERSION HISTORY


      Sl No

      Version No.

      Prepared by

      Approved by

      Description of Version

      Date

      Reason for Version Change

      From

      To

      1

      1.0

      -

      CISO

      MD

      First Release

      14 Apr 2020 

      No changes made

      1

      1.0

      1.1

      CISO

      MD

      Updated

      21 Jun 2021 

      Modifications due to changes in HealthSafe

      1

      1.1

      1.2

      CISO

      MD

      Reviewed

      27 Jul 2022 

      Annual review
      1 1.2 1.3 CISO MD Reviewed 15 Aug 2023 Annual review

      DOCUMENT STATUS


      Date

      Document Status

      14 Apr 2020

      Modified

      21 Jun 2021

      Reviewed

      27 Jul 2022

      Reviewed

      15 Aug 2023

      Current






      Table of Contents

      1 Purpose


      2 Scope


      3 Input


      4 Output


      5 Interacting Process


      6 Abbreviations, Acronyms and Definitions


      7 Procedure


      8 Monitoring the Process


      9 Records






      1 PURPOSE


      This policy is designed to help and encourage all employees, trainees and contractors to achieve and maintain standards of conduct and to deter employees who disregard HealthSafe NZ policies 


      2 SCOPE


      This procedure applies to all employees whether employed on full-time, part-time or fixed term contracts irrespective of their length of service and trainees


      3 INPUT


      Memo / Warning


      4 OUTPUT


      Termination / Penalty


      5 INTERACTING PROCESS


      Finance, Functional Head, Employee, Contractors, Vendors


      6 ABBREVIATIONS, ACRONYMS AND DEFINITIONS


      Abbreviation

      Description

      FH

      Functional Head

      IT

      Information Technology Department

      TL

      Team Lead

      CISO

      Chief Information Security Officer

      7 PROCEDURE


      HealthSafe NZ is committed to the highest ethical standards and compliance with all applicable laws and regulations.  It is the obligation of HealthSafe NZ employees to conduct themselves honestly and ethically to avoid conflicts of interest, disclose to their immediate superiors any relationship that appears to constitute a conflict of interest and comply with applicable governmental laws, rules and regulations.


      Ethical Business Practices


      HealthSafe NZ requires that the employees maintain lawful and ethical business practices at all times by being fair and transparent in all dealings by inculcating and practising Openness, Collaboration, Trustworthiness, Authenticity, Proactive, Autonomy, Confrontation & Experimentation.


      Examples of certain prohibited activities are set forth below. These examples are intended to highlight some prohibited practices, but they do not address every kind of prohibited practice.


      Funds and Property


      Use of HealthSafe NZ funds or property for illegal, purposes is prohibited. 


      Gifts and Entertainment


      Employees and members of their families must not solicit nor accept loans, fees, services, or monetary gifts of any kind from suppliers, customers, or others dealing with HealthSafe NZ. They may accept unsolicited non-monetary gifts or entertainment which conform to customary business practices and are not of significant value. 


      Conflicts of Interest and Outside Associations and Activities


      Employees have a duty to disclose to immediate superiors, any business, financial, or other professional relationships that might conflict with HealthSafe NZ’s interests or impair or influence their ability to discharge their duties. There are potential conflicts of interest inherent in certain situations such as when:


      • An employee or a member of the employee’s family has a direct or indirect financial interest in, or obligation to, an actual or potential competitor, supplier, or customer. (This does not include small stock ownership in publicly traded companies).

      • Employees conduct business on behalf of HealthSafe NZ with a supplier or customer in whom a relative of the employee is a representative, officer or director.

      • Employees acquire real property, leaseholds, patents, or other property or rights in which HealthSafe NZ has, or employees have reason to believe that HealthSafe NZ is likely to have an interest.

      Confidential Information 


      As a general matter, inside information is any material, non-public information concerning HealthSafe NZ or its business Information may be considered “material” if it would likely be considered important to an investor in deciding whether to purchase or sell HealthSafe NZ’s interest, if the information were publicly released. For example, internal information might include information relating to proposed acquisitions, important financial data, major new contracts, research projects, the status of a product in the governmental approval process, or significant management changes. Even after information is publicly released, it should still be considered non-public until a sufficient amount of time has passed for the information to become generally available to, and absorbed by, the investing public. While the amount of time that must pass for information to be considered public may vary depending on the circumstances, generally, information may be considered to be public 72 hours following its release to the investing public.


      Protecting the Environment and Employee Health and Safety


      It is HealthSafe NZ's policy to protect the environment and safeguard the health and safety of employees where applicable. HealthSafe NZ conducts its operations so to avoid or minimise any possible adverse impact on the environment or employees and expects all employees to obey those laws that are designed to protect the environment and the health and safety of employees where applicable. All employees are expected to notify their supervisor, if they observe conduct which violates, or is likely to violate, environmental, health, or safety requirements.


      Privacy


      HealthSafe NZ is committed to protecting the integrity and privacy of personal data and other private information related to individuals coming into the possession of it or its employees.


      All employees are expected to comply with privacy requirements appropriately. In addition, each employee is responsible for developing procedures governing the proper collection, storage and use of personal data.


      Systems/E-Mail/Internet Policy


      All HealthSafe NZ supplied computer systems, including computer hardware and software programs, and HealthSafe NZ related proprietary, confidential, or privileged information, are the property of HealthSafe NZ and not the employees.  These systems, including Email should be used for HealthSafe NZ business only and should not be used to transmit unsecured HealthSafe NZ related proprietary, confidential, or privileged information outside HealthSafe NZ, without a proper business purpose, appropriate security measures, and appropriate authorisation. If employees have any questions concerning the sensitivity, confidential classification, and/or protection of HealthSafe NZ information, they should first speak to their Functional Head before transmitting information outside HealthSafe NZ.  HealthSafe NZ has the right to monitor any employee's Email and Internet usage.


      Sexual/racial Harassment


      HealthSafe NZ is committed to maintaining a professional work environment and strongly disapproves of all forms of sexual/racial discrimination.  Employees who believe they have been subjected to sexual/racial harassment/abuse or who have witnessed should report such incidents to their Functional Head. If an employee is uncomfortable reporting the incident to designated authorities, he or she should contact any other officer of HealthSafe NZ, who shall appropriately communicate the same to the designated authorities.


      Cooperating with Government Authorities


      It is the policy of HealthSafe NZ to cooperate with Governmental investigations or inquiries. Accordingly, if employees reasonably believe that a Government investigation or inquiry is in progress, they should communicate that information immediately to the concerned authorities.


      The employees should never:


      • Destroy or alter any HealthSafe NZ documents in anticipation of a request for those documents from any government agency or judicial authority.

      • Make any false or misleading statements to any governmental investigator during an investigation.

      • Attempt to cause any other HealthSafe NZ employee or any other person to fail to provide information to a government investigator, or to provide false or misleading information.

      CODE OF CONDUCT


      1. All employees are required to devote themselves exclusively to the HealthSafe NZ’s business and during their employment with HealthSafe NZ.  No employee should be engaged in any trade, business or profession, either directly or indirectly other than that of the HealthSafe NZ unless permitted by HealthSafe NZ in writing to do so.

      1. During the employment with HealthSafe NZ or after termination of such employment no employee should divulge to anyone any information, relating to the HealthSafe NZ’s business or the business of any of HealthSafe NZ’s subsidiaries or associated agencies.

      1. If during the employment with HealthSafe NZ, employees either wholly or partly discover, invent and/or make improvements in software, innovations, process or other things used or may be used in the production or business of the HealthSafe NZ, the same will be deemed to have been made, invented, suggested or acquired on behalf of and for the benefit of the HealthSafe NZ alone and all rights, privileges and titles will rest only with HealthSafe NZ.

      1. Use of alcohol, tobacco, etc, is prohibited in any HealthSafe NZ premises unless permitted by an authorised person.

      1. Employees should not borrow money from any of the customers of HealthSafe NZ or from anyone trading with HealthSafe NZ.

      NON-DISCLOSURE/CONFIDENTIALITY


      The protection of confidential business information and trade secrets is vital to the interests of HealthSafe NZ, which shall be protected by every employee. Such confidential information includes, but is not limited to, the following examples:


      • Customer data,
      • Financial information,
      • Marketing strategies,
      • Pending projects and proposals,
      • Proprietary production processes,
      • Proprietary software innovations,
      • Personnel/Payroll records, and
      • Conversations between any persons associated with HealthSafe NZ.

      All employees are required to sign a non-disclosure or be included in their employment agreement as a condition/corollary of their employment with HealthSafe.


      Employees who improperly use or disclose trade secrets or confidential business information will be subject to disciplinary action, including termination of employment and legal action, even if they do not actually benefit from the disclosed information.


      Duty to Report Violations


      Employees are responsible for reporting in good faith to HealthSafe NZ, any circumstances that the employee believes may constitute a violation of this Code of Ethics. Employees should report suspected violations to the immediate supervisor or Functional Head, who will investigate these matters. 


      There will be no action taken against the employee for good faith reporting of suspected policy violations; however, the employee will not be protected from possible disciplinary action if the report is in bad faith or the employee has otherwise engaged in misconduct.


      Enforcement


      If any employee commits a breach of any of the conditions as laid by HealthSafe NZ or is guilty of misconduct or conducts them in a manner that would bring HealthSafe NZ or its employees into disrepute, they will be subject to an open and transparent investigation in order to determine if HealthSafe NZ policies or procedures have been deliberately not followed.


      In addition, the employee may be liable to pay HealthSafe NZ on demand, such sum of money towards liquidated damages and HealthSafe NZ shall also be entitled to initiate appropriate criminal proceedings or pursue injunctive relief against the employee.  


      Disciplinary Procedure


      The Formal Disciplinary Procedure will follow the process as advised by Employment New Zealand: 

      • Consider if there is a good reason to start a disciplinary process
      • Inform the employee of the problem
      • Investigate the problem
      • Formal meeting
      • Further investigations (if required)
      • Second formal meeting (if required)
      • Consideration of action to be taken
      • Preliminary decision
      • Final decision

       

      Verbal  Warning


      This is applicable for minor infringements of policies and procedures when informal discussions or counselling have failed to bring about the desired improvement in conduct or work performance.


      Written Warning


      This is applicable to serious infringements.


      A copy of the written warning should be kept on the employee file and expunged after a maximum of 12 months. This could be brought forward on the Functional Head’s recommendation subject to satisfactory review after 6 and 9 months.


      Dismissals or Other Sanction


      If the decision to dismiss, including for Gross Misconduct, is taken by the Top Management, the employee should be informed in writing within 3 days of being told verbally his employment is to be terminated.


      The letter should incorporate the following*:-


      • The reasons for the dismissal.
      • Refer to previous disciplinary warnings.
      • The date on which the employment contract will terminate.
      • The appropriate period of notice (or pay in lieu of notice) to be given (Excluding cases of Gross Misconduct where summary dismissal applies).
      • How and to whom an appeal can be made.

      *see Employment NZ advice on the latest templates of letters


      GROSS MISCONDUCT (Refer to List of gross misconduct given below)


      If, after investigation, an offence is identified as gross misconduct the normal consequences can be dismissal without notice and without pay in lieu of notice. As an alternative to dismissal, the Disciplinary Officer may offer the following action:


      • Transfer to another role where the shortfall in performance conducts would not be relevant
      • Disciplinary suspension (without pay) for a defined period
      • De-promotion / loss of seniority
      • Final Written Warning

      Where the timescales for improvement given on the Final Warning have elapsed and the employee has not reached the standard of work performance, or where there are continued breaches of conduct, the employee may be dismissed with the appropriate notice period or pay in lieu of notice.


      GROSS MISCONDUCTS INCLUDE:


      • Serious breach of confidentiality
      • Theft, fraud, deliberate falsification, modification or omission of information for gain
      • Unauthorised access, use or possession of the organisation’s property and facilities
      • Deliberate damage to organisation’s information assets or that of fellow employees
      • Sexual or racial harassment or bullying
      • Being unfit for work through the use of alcohol or illegal drugs
      • Unauthorised possession/supply of illegal drugs to oneself or others
      • Gross negligence causing unacceptable loss/damage or injury
      • Wilful malicious or vexatious conduct
      • Violent/abusive behaviour
      • Deliberate disregard of Safety and security procedures
      • Acceptance of bribes/financial breach of trust
      • Criminal offences punishable by the Criminal law of the Country
      • This list is not definitive.
      • In serious cases of misconduct the process should allow for instant removal of duties, access rights and privileges, and for immediate escorting out of the site, if necessary.

      8 MONITORING THE PROCESS


      Day-to-day and routine proactive monitoring and reactive monitors such as complaints, breaches, incidents etc.


      9 RECORDS


      • Employee Code of Conduct