Privacy Policy

Medical Trust Corporation respects the expertise of Health Care Professionals who provide guidance about health care treatment options and healthy living in compliance with our mission.

To leave a legacy of excellence and transparency by partnering with healthcare professionals to facilitate and provide quality services for our patients.

We are committed to working with partners that provide and deliver safe, effective products that people trust. We at Medical Trust endeavor to have a high level of quality throughout our business. Our Business is built on Respect, Honesty, Trust, and Loyalty

Medical Trust’s Policy is to engage in business practices in full compliance the foreign Corrupt Practice Act of 1977 (FCPA) in the United States, the Corruption of Foreign Public Officials Act (CFPOA) and the Anti-Bribery Act together with all other anti-corruption anti-bribery laws and regulations applicable to Medical Trust’s business anywhere in the world.

Medical Trust will comply with Laws and Industry Codes that are all applicable legal requirements and industry codes. This includes, but is not limited to, anti-bribery and anti-corruption laws, competition and unfair business practices laws, restrictions on advertising activities, and any laws, regulations and codes that govern interactions with Health Care Professionals (HCPs), Health Care Institutions (HCIs) and Government Officials (GOs).

• HCPs are any medically licensed or scientifically trained professionals using or expected to use such license or training in his or her work providing health care, any person making purchasing or usage decisions about Abbott products for an HCI.
• HCIs are any entities, facilities, institutions, foundations, associations, or organizations that employ HCPs or sites where HCPs provide health care to patients.
• GOs are any persons who are employed by an entity that is owned, controlled, funded, or operated by any level of government in any country as well as any persons acting as government agents or representatives.

Interactions with HCPs, HCIs, and GOs.

Medical Trust is committed to doing business the right way when marketing or selling the products we represent. Medical Trust will not take any actions that could interfere with the independent, professional judgment of the HCPs, HCIs or GOs that purchase, prescribe products. This includes the following:

1. The Right Basis for Interactions. Nothing of value will be provided or offered, including those (1) get or reward a sale; (2) reward any past or existing relationship; (3) reward any action taken by the recipient; (4) influence any future decision or action taken by the recipient; (5) obtain or retain business; or (6) direct business to any person or away from any person. This is not limited to payments of money, and includes offering or providing things such as gifts, travel, meals, lodging, grants, speaker fees, donations, and sponsorships.
2. Medical Sponsorships. If allowed by applicable laws and industry codes, Medical Trust may provide support for HCPs to attend third party educational, scientific, and public policy conferences and similar meetings. Recipients of such support must have appropriate qualifications, as well as legitimate training or educational needs. Financial support should be limited to conference registration fees and reasonable travel, meals, and accommodation associated with attendance at the conference. Standalone sightseeing, entertainment, leisure, or social activities may not be paid for or provided.
3. Meals and Travel. If allowed by applicable laws and industry codes, HCPs may be provided with modest meals and may be reimbursed for reasonable travel expenses (accommodation, meals, transportation, visa, insurance, and registration) in connection with a training event or legitimate business occasion. Meals and travel expenses cannot be provided to guests, spouses, or family members of HCPs. Travel to venues known primarily for gambling, entertainment, spa, or sporting activities is not allowed. Personal expenses incurred by an HCP or other recipient of travel support, such as fitness center charges, spa fees, or side trips may not be paid for or reimbursed.
4. Professional Services Arrangements. If allowed by applicable laws and industry codes, HCPs can be paid for providing bona fide professional services such as speaking at conferences and physician training sessions. However, the HCP must be appropriately qualified, there must be a legitimate business need for the services, fees must be based on fair market value, and services must be provided in accordance with a written agreement.
5. Charitable Contributions. If allowed by applicable laws and industry codes, contributions to organizations or entities for charitable purposes (such as improving delivery of healthcare, increasing access to healthcare technology) and humanitarian assistance may be provided.
6. Facilitation Payments. Facilitation payments are not allowed. A facilitation payment is a payment to a GO that is intended to expedite a routine government Abbott Third-Party Guidelines 3 action that the official or employee is already bound to perform (for example, obtaining permits, licenses, or other official documents to qualify a person to do business in a country, processing visa applications, scheduling inspections associated with contract performance or a regulatory application, or providing phone service, power or water supply).
7. Facilitation Payments. Facilitation payments are not allowed. A facilitation payment is a payment to a GO that is intended to expedite a routine government Abbott Third-Party Guidelines 3 action that the official or employee is already bound to perform (for example, obtaining permits, licenses, or other official documents to qualify a person to do business in a country, processing visa applications, scheduling inspections associated with contract performance or a regulatory application, or providing phone service, power or water supply).

Bribery

Medical Trust has zero tolerance for any corruption in business activities. Bribes or other improper or unauthorized payments that directly or indirectly make, offer, or promise to make, kickbacks, benefits, or advantages to any person, individual, organization, or entity, are prohibited by this Policy. A violation of this Policy can occur even if a bribe or other corrupt practice fails to achieve the desired outcome.

Personnel is expected to adhere to both the spirit and the letter of this Policy concerning all aspects of the company’s business anywhere in the world. It is the responsibility of Personnel to be aware of how each situation may violate or lead to a violation of this Policy and Anti-Corruption Laws.

Gifts

Gifts are commonly offered as a gesture of gratitude or tokens of appreciation, but in some situations, they can also be construed as bribes.

Personnel must ensure that any gifts are of value in proportion to the situation at hand, and any gifts should be infrequent to avoid being perceived as an attempt to influence an act or a decision. When offering or accepting a gift, Personnel should specifically consider the following:

• The Intended Outcome: Gifts can have many purposes, such as expressing appreciation and building relationships, but they can also be viewed as an attempt to influence a direct result e.g., to win a bid or affect the negotiation process.
• The Company’s Reputation: The gift may be a private act, but if it were to come to the public’s attention, Personnel should consider how it would affect the reputation of Medical Trust
• Competition: A general rule of thumb is to think about how Medical Trust would perceive a similar gift made by a competitor.

Disciplinary Action

If Personnel should fail to comply with this Policy or Anti-Corruption Laws, they will be subjected to disciplinary action up to including termination of employment or other relationship with Medical Trust. Restitution could also be required, and civil or criminal action against individual personnel could be warranted.

If Personnel is involved in or aware of the situation they believe may violate or lead to a violation of this Policy, they must ask for guidance from their manager or other personnel ia a superior position.