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Sample Code of Conduct - Private Sector

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Sample Code of Conduct - Private Sector (Mar 2019).pdf

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Sample Code of Conduct - Private Sector (Mar 2019).doc

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Pharmaceutical and Medical Device

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Corruption Risks

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Offering donations to research institutions or healthcare professionals with the aim of securing favourable consideration of a product in the research and development process.
Offering advantages to public servants to expedite patent applications or product registration processes.
Offering advantages to auditors in exchange for the certification of pharmaceutical products or medical devices (e.g. GMP certification, ISO certification).
Accepting advantages from suppliers in return for procuring products or product ingredients.
Accepting advantages from suppliers in exchange for assisting them in inflating the prices of medical products or for conniving at their substandard quality.

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Offering advantages to healthcare professionals in return for recommending particular drugs or medical equipment in assessment processes or drug enlistment applications.
Obtaining confidential tendering information by offering advantages to healthcare professionals involved in the process.
Sponsoring healthcare professionals to attend overseas conferences in exchange for using or recommending the company’s products.
Providing frequent or lavish entertainment to healthcare professionals who have the authority to recommend or select drugs or medical devices for their respective institutions.
Accepting advantages from clients in exchange for allocating high-demand products on a preferential basis.
Diverting business to competitors or companies in which one has a financial interest in return for rebates.
Accepting advantages in exchange for disclosing proprietary information to competitors.

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Accepting advantages from contractors in return for placing service orders (e.g. logistics services for product delivery).
Accepting advantages in exchange for granting discounts or benefits to ineligible clients.
Providing excessive product samples to healthcare professionals for improper purposes.
Falsifying stock or inventory records to conceal the pilferage of product samples or promotional items.
Abusing staff purchase schemes by reselling products for personal gain.

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Having financial interest in a medical supplies company that is a potential supplier.
Handling procurement matters where one of the tendering or bidding companies is operated by a relative.
Serving on a recruitment panel while a close personal friend is one of the candidates.
Undertaking part-time employment with a competitor or a contractor.

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Case Studies

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The Hong Kong Association of the Pharmaceutical Industry – Code of Practice

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Hong Kong MedTech Association

Integrity Training

The Private Sector Integrity Centre (PSIC) offers free anti-corruption and integrity training to help pharmaceutical and medical device industries build an ethical corporate culture and prevent corruption and fraud.

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General Staff

Remain vigilant against corruption risks in daily work

Enhance their knowledge of anti-corruption law

Acquire skills to make ethical decision

Managers

Recognise their managerial role in preventing corruption

Develop the ability to identify and manage corruption risks in daily operations

Acquire practical tips for managing staff integrity

Senior Management

Enhance awareness of the importance of ethical leadership

Stay alert to common red flags and corruption loopholes

Adopt best practices for preventing corruption and fostering an ethical culture

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PSIC organises webinars on the “PSIC Channel” for business practitioners across various sectors and industries. Click here to view details of the upcoming webinars and enroll now!

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User-friendly e-learning materials are available:

Online Ethics Resources for the Pharmaceutical and Medical Device Industries

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PSIC provides free, tailor-made training for pharmaceutical and medical device representatives.

Please contact us if you wish to arrange integrity and corruption prevention training.

introduction

The demand for medical and healthcare products and services has significantly increased in recent years, and the quality of these products and services remains a key public concern. Practitioners of the medical and healthcare industries should maintain high integrity standards for ensuring service and product quality, as well as sustaining their goodwill, public trust and competitive edge in the market.

The Private Sector Integrity Centre (PSIC) offers anti-corruption and integrity training to help practitioners remain vigilant to corruption risks and uphold high integrity standards. We also provide corruption prevention advisory services and practical resources to help professions and companies strengthen safeguards and foster an ethical culture.

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Medical and Healthcare

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Medical Service

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Corruption Risks

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Accepting gifts from patients in defiance of the policies or guidelines of the respective medical institutions.
Accepting advantages from patients in return for assisting them in securing earlier appointments.
Accepting advantages from patients in exchange for preferential treatment.
Soliciting or coercing patients to pay bribes to ensure proper treatment.

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Using false medical receipts to charge patients unnecessary or inflated fees for services, tests or medication.
Misappropriating all or part of service fees by fabricating appointment or service records.
Misleading patients into making payments for services that should be provided free of charge.

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Falsifying medical or patient records to justify billing, conceal malpractice, or inflate performance indicators.
Colluding with patients to submit fraudulent claims for medical expenses or sick leave by issuing false medical certificates to their employers.
Conspiring with policyholders or insurance intermediaries to submit fraudulent insurance claims supported by fabricated medical reports.
Providing medical services to ineligible persons to fraudulently obtain government subsidies.
Accepting advantages in exchange for disclosing patient data to salespersons or insurance intermediaries for marketing purposes.

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Accepting rebates from pharmaceutical or medical device companies in return for recommending their drugs or equipment.
Accepting commissions or referral fees for directing patients to designated laboratories.
Accepting advantages in exchange for referring patients for unnecessary tests or to specific specialists.

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Accepting sponsorships from pharmaceutical or medical device companies to attend overseas conferences in return for recommending their products or services.
Accepting advantages from suppliers for assisting them in securing contracts (e.g. by leaking prices of other bidders).
Accepting advantages from suppliers in exchange for helping them inflate the prices of medical products or conniving at substandard quality.

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Stealing medicines or medical equipment for resale.
Tampering with stock or inventory records to conceal misappropriation of medical supplies.

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Accepting advantages in return for hiring or promoting unqualified individuals.
Accepting advantages from subordinates in exchange for assigning favorable shifts or duties.
Accepting advantages from subordinates for giving favourable performance appraisals.
Colluding with other staff members to falsify attendance records in order to inflate wages, overtime allowances or other benefits.

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Prioritising family members, friends or associates over ordinary patients when providing services or granting them preferential treatment.
Referring patients for medical check-ups to a private medical centre in which you have a personal financial interest.
Recommending drugs or medical supplies represented by personal friends or relatives to hospitals or clinics.
Approving tenders or quotations submitted by relatives or close friends.
Prioritising private patients over public patients when practising in both sectors.

Resources

Case Studies

Practical Guides

Feature Articles and Newsletters

Publicity Materials

107

Sample Documents

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The Medical Council of Hong Kong - Code of Professional Conduct

Integrity Training

The Private Sector Integrity Centre (PSIC) offers free anti-corruption and integrity training to help hospital and medical institutions build an ethical corporate culture and prevent corruption and fraud.

fade-up

General staff

Remain vigilant against corruption risks in daily work

Enhance their knowledge of anti-corruption law

Acquire skills to make ethical decision

Managers

Recognise their managerial role in preventing corruption

Develop the ability to identify and manage corruption risks in daily operations

Acquire practical tips for managing staff integrity

Senior Management

Enhance awareness of the importance of ethical leadership

Stay alert to common red flags and corruption loopholes

Adopt best practices for preventing corruption and fostering an ethical culture

fade-up

container

PSIC organises webinars on the “PSIC Channel” for business practitioners across various sectors and industries. Click here to view details of the upcoming webinars and enroll now!

fade-up

container

User-friendly e-learning materials are available:

“Integrity in Practice” Online Guide for Medical Professionals

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container

PSIC provides free, tailor-made training for medical and healthcare service practitioners.

Please contact us if you wish to arrange integrity and corruption prevention training.

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2. What type of organisation do you represent?

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3. What is the size of your organisation?

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Sample Code of Conduct - Private Sector

Pharmaceutical and Medical Device

Pharmaceutical and Medical Device

Corruption Risks

Product Development and Manufacturing

Sales and Marketing

Product Distribution

Conflict of Interest

Resources

Other Reference

Integrity Training

Training Objectives

Online Training

E-learning

Tailor-made Training

Medical Service

Medical Service

Corruption Risks

Provision of Medical Services

Billing and Collection of Service Fees

Management of Medical / Patient Records

Referral of Businesses

Procurement

Inventory Management

Staff Administration

Conflict of Interest

Resources

Other Reference

The Medical Council of Hong Kong - Code of Professional Conduct

Integrity Training

Training Objectives

Online Training

E-learning

Tailor-made Training