Anti-Bribery & Anti-Corruption Policy

1. Policy Statement

The Smart T Web Hospital, as Gujarat's Top #1 Hospital Healthcare Solution Point, is committed to conducting all business activities with the highest standards of integrity, transparency, and ethical conduct. We have zero tolerance for bribery, corruption, and any form of unethical behavior that could compromise patient care, professional judgment, or public trust in our healthcare services.

Since our establishment in 2012, we have built our reputation on providing excellent healthcare while maintaining unwavering ethical standards. This Anti-Bribery and Anti-Corruption Policy (ABAC Policy) demonstrates our commitment to compliance with all applicable anti-corruption laws, regulations, and international best practices in healthcare governance.

All employees, contractors, vendors, partners, and associates of The Smart T Web Hospital are required to understand, comply with, and actively support this policy. Violation of these principles will result in appropriate disciplinary action, up to and including termination of employment or business relationships, and may lead to civil or criminal prosecution.

This policy applies to all our operations, including our 100-bedded facility, 24/7 emergency services, outpatient clinics, diagnostic services, and all interactions with patients, suppliers, government officials, and healthcare professionals.

2. Scope of Application

2.1 Personnel Coverage

This policy applies to all individuals associated with The Smart T Web Hospital, including:

• All permanent, temporary, and contract employees
• Medical staff, including doctors, nurses, and healthcare professionals
• Administrative personnel and management
• Board members and advisory committee members
• Consultants, advisors, and independent contractors
• Volunteers and interns
• Business partners and joint venture participants
• Suppliers, vendors, and service providers

2.2 Operational Coverage

The policy covers all business activities and operations, including:

• Patient care and medical service delivery
• Procurement of medical equipment, supplies, and services
• Pharmaceutical and medical device interactions
• Government relations and regulatory compliance
• Insurance claim processing and billing
• Research activities and clinical trials
• Marketing and promotional activities
• Charitable activities and community outreach

2.3 Geographic Coverage

This policy applies to all activities conducted by or on behalf of The Smart T Web Hospital, whether within India or internationally, and must be followed regardless of local customs or practices that may be inconsistent with these standards.

3. Definitions and Key Terms

3.1 Bribery

Bribery means offering, promising, giving, accepting, or soliciting anything of value to influence the actions of an official or other person in a position of trust, or to secure an improper advantage. This includes both direct and indirect forms of bribery.

3.2 Corruption

Corruption refers to the abuse of entrusted power for private gain. It includes bribery, extortion, fraud, nepotism, and other forms of dishonest or unethical conduct that compromise integrity in decision-making processes.

3.3 Facilitation Payments

Small payments made to secure or expedite routine governmental actions, such as processing licenses, permits, or other administrative functions. These are prohibited under this policy regardless of local practices.

3.4 Government Official

Any person employed by or acting on behalf of a government agency, department, or public international organization, including healthcare regulators, licensing authorities, tax officials, and employees of public hospitals or healthcare institutions.

3.5 Third Party

Any individual or entity that provides services to or acts on behalf of The Smart T Web Hospital, including agents, consultants, distributors, suppliers, contractors, and business partners.

3.6 Anything of Value

This includes money, gifts, loans, rewards, favors, services, entertainment, hospitality, employment opportunities, discounts, and any other benefit or advantage, regardless of monetary value.

4. Legal Framework and Compliance

4.1 Applicable Laws and Regulations

The Smart T Web Hospital complies with all applicable anti-bribery and anti-corruption laws, including:

• The Prevention of Corruption Act, 1988 (India)
• The Indian Penal Code provisions on corruption
• The Companies Act, 2013 and related corporate governance requirements
• Healthcare-specific regulations and licensing requirements
• International standards and best practices
• Any other applicable local, state, or national anti-corruption legislation

4.2 Regulatory Compliance

We maintain active compliance with healthcare regulatory bodies, including:

• Medical Council of India (MCI) guidelines
• Central Drugs Standard Control Organization (CDSCO) regulations
• State health department requirements
• Insurance regulatory authority guidelines
• Clinical establishment standards and accreditation requirements

5. Prohibited Activities

5.1 Direct and Indirect Bribery

The following activities are strictly prohibited:

• Offering, promising, or giving bribes to any person or entity
• Accepting or soliciting bribes from any source
• Using third parties to offer or accept bribes on our behalf
• Making payments with the knowledge that they will be used for bribery
• Providing excessive hospitality or gifts that could influence decision-making
• Offering employment or business opportunities as inducements

5.2 Kickbacks and Referral Fees

Healthcare-specific prohibited activities include:

• Paying or receiving kickbacks for patient referrals
• Providing financial incentives for prescription of specific medications
• Offering inducements for use of particular medical devices or equipment
• Participating in fee-splitting arrangements that compromise patient care
• Engaging in self-referral practices that create conflicts of interest

5.3 Fraud and Misrepresentation

• Submitting false claims to insurance providers or government programs
• Misrepresenting qualifications, certifications, or accreditations
• Falsifying medical records or billing information
• Providing misleading information about treatment outcomes or costs
• Engaging in price manipulation or anti-competitive practices

6. High-Risk Areas in Healthcare

6.1 Pharmaceutical and Medical Device Relationships

Special attention must be paid to relationships with pharmaceutical companies and medical device manufacturers, including:

• Educational programs and conference sponsorships
• Research grants and clinical trial funding
• Consulting arrangements and advisory board memberships
• Equipment loans and demonstration programs
• Marketing and promotional activities

6.2 Government and Regulatory Interactions

Interactions with government officials require careful management:

• Licensing and permit applications
• Regulatory inspections and compliance reviews
• Government healthcare program participation
• Public procurement processes
• Policy advocacy and regulatory submissions

6.3 Insurance and Third-Party Payers

• Claims processing and reimbursement procedures
• Network participation agreements
• Prior authorization and utilization review processes
• Quality reporting and performance metrics
• Dispute resolution and appeals procedures

7. Gifts, Hospitality, and Entertainment

7.1 General Principles

All gifts, hospitality, and entertainment must be:

• Reasonable in value and appropriate for the business relationship
• Transparent and properly documented
• Infrequent and not part of a pattern that could create obligations
• Compliant with applicable laws and professional standards
• Approved by appropriate management levels

7.2 Acceptable Gifts and Hospitality

The following may be acceptable when they meet the general principles:

• Modest promotional items with minimal value
• Reasonable business meals in appropriate settings
• Educational materials and medical literature
• Professional conference attendance with legitimate educational value
• Cultural exchanges and ceremonial gifts of minimal value

7.3 Prohibited Gifts and Hospitality

• Cash or cash equivalents, including gift cards
• Expensive gifts or entertainment that could create obligations
• Personal favors or services
• Lavish hospitality or entertainment
• Gifts to family members or personal friends
• Any gift or hospitality that violates local laws or professional codes

8. Facilitation Payments

8.1 Policy on Facilitation Payments

The Smart T Web Hospital strictly prohibits all facilitation payments, also known as "speed money" or "grease payments." These are small payments made to secure or expedite routine services that the payer is legally entitled to receive without such payment.

8.2 Examples of Prohibited Facilitation Payments

• Payments to expedite license renewals or permit applications
• Money given to speed up routine inspections or approvals
• Payments to ensure timely utility connections or services
• Tips or payments to government employees for standard services
• Payments to customs or immigration officials for routine clearances
• Money given to expedite certificate issuances or registrations

8.3 Emergency Exceptions

In rare emergency situations where personal safety is at immediate risk, facilitation payments may be made under duress. Such incidents must be:

• Reported immediately to the Compliance Officer
• Fully documented with circumstances and justification
• Recorded accurately in financial records
• Investigated to prevent future occurrences
• Reported to appropriate authorities if required

8.4 Alternative Approaches

Instead of making facilitation payments, personnel should:

• Allow normal processing times for routine services
• Escalate delays through proper official channels
• Seek assistance from senior management or legal counsel
• Document any requests for improper payments
• Report corrupt practices to appropriate authorities

9. Third-Party Relationships

9.1 Due Diligence Requirements

Before engaging any third party to act on behalf of The Smart T Web Hospital, appropriate due diligence must be conducted to assess:

• Business reputation and integrity
• Ownership structure and beneficial ownership
• Previous involvement in corruption or legal violations
• Financial stability and business practices
• Compliance with applicable laws and regulations
• Potential conflicts of interest

9.2 Contractual Requirements

All agreements with third parties must include:

• Clear anti-bribery and anti-corruption clauses
• Compliance with all applicable laws and this policy
• Right to audit and monitor compliance
• Obligation to report suspected violations
• Termination rights for policy violations
• Indemnification provisions for non-compliance

9.3 Ongoing Monitoring

Third-party relationships require continuous oversight through:

• Regular performance reviews and compliance assessments
• Annual certification of continued compliance
• Periodic re-evaluation of due diligence information
• Investigation of any red flags or suspicious activities
• Training and communication of policy updates

9.4 Red Flags in Third-Party Relationships

• Requests for cash payments or payments to third countries
• Unusual payment methods or offshore account requirements
• Reluctance to provide due diligence information
• Family or business relationships with government officials
• History of regulatory violations or legal issues
• Excessive fees compared to services provided

10. Charitable Contributions and Sponsorships

10.1 Legitimate Charitable Activities

The Smart T Web Hospital supports legitimate charitable activities that align with our mission of improving community health. All charitable contributions must be:

• Made to registered and legitimate charitable organizations
• Transparent and properly documented
• Approved through established authorization procedures
• Not used to circumvent anti-bribery laws
• Consistent with applicable tax laws and regulations

10.2 Prohibited Charitable Activities

• Contributions to charities controlled by government officials
• Donations made at the request of public officials
• Charitable contributions that coincide with business negotiations
• Payments to organizations without legitimate charitable purposes
• Contributions used to influence business decisions
• Donations that violate local laws or regulations

10.3 Sponsorship Guidelines

Medical conferences, educational events, and healthcare initiatives may be sponsored when:

• There is clear educational or scientific value
• Sponsorship terms are transparent and documented
• Benefits received are proportional to sponsorship amount
• No quid pro quo arrangements are involved
• Compliance with professional medical association guidelines

11. Political Activities and Contributions

11.1 Corporate Political Activities

The Smart T Web Hospital maintains political neutrality and does not make corporate political contributions or engage in partisan political activities. This includes:

• Direct contributions to political parties or candidates
• Indirect support through third parties
• Provision of services or resources for political campaigns
• Participation in partisan political events or rallies
• Use of corporate resources for political activities

11.2 Personal Political Activities

While employees have the right to participate in personal political activities, they must:

• Ensure activities are conducted on personal time
• Use personal resources, not company resources
• Clearly distinguish personal views from hospital positions
• Avoid creating conflicts of interest with hospital operations
• Not use hospital name or position for political endorsements

11.3 Government Relations and Advocacy

Legitimate government relations and policy advocacy may be conducted when:

• Focused on healthcare policy issues relevant to operations
• Conducted transparently and in accordance with lobbying laws
• Properly disclosed and registered as required
• Not involving improper payments or inducements
• Approved by senior management and legal counsel

12. Procurement and Vendor Selection

12.1 Fair and Transparent Procurement

All procurement activities must be conducted fairly, transparently, and based on merit. This includes:

• Open and competitive bidding processes where appropriate
• Clear evaluation criteria and documentation of decisions
• Separation of duties in procurement processes
• Avoiding conflicts of interest in vendor selection
• Proper authorization and approval procedures

12.2 Vendor Due Diligence

Before engaging vendors or suppliers, appropriate due diligence must include:

• Verification of business licenses and certifications
• Assessment of financial stability and business reputation
• Review of compliance with applicable laws and standards
• Background checks on key personnel
• Evaluation of quality management systems
• Assessment of anti-corruption policies and procedures

12.3 Contract Management

All vendor contracts must include:

• Clear specifications for goods and services
• Transparent pricing and payment terms
• Anti-bribery and anti-corruption clauses
• Compliance certification requirements
• Right to audit and monitor performance
• Termination provisions for policy violations

12.4 Ongoing Vendor Management

• Regular performance evaluations and compliance reviews
• Monitoring of red flags or suspicious activities
• Annual compliance certifications
• Investigation of complaints or concerns
• Corrective action plans for deficiencies

13. Financial Controls and Record Keeping

13.1 Accurate Financial Records

The Smart T Web Hospital maintains accurate, complete, and transparent financial records in accordance with applicable accounting standards and regulations:

• All transactions must be properly authorized and documented
• Expenses must be accurately recorded and categorized
• Supporting documentation must be maintained for all transactions
• Regular reconciliation and review procedures must be followed
• No off-the-books accounts or unrecorded transactions are permitted

13.2 Internal Controls

Robust internal controls are maintained to prevent and detect corruption:

• Segregation of duties in financial processes
• Multiple approval levels for significant transactions
• Regular internal audits and compliance reviews
• Exception reporting and investigation procedures
• Periodic review and updating of control procedures

13.3 Expense Management

All business expenses must be:

• Legitimate business expenses with proper justification
• Supported by appropriate documentation
• Approved by authorized personnel
• Recorded accurately in financial systems
• Subject to regular review and audit

13.4 Cash Management

• Minimize cash transactions where possible
• Proper authorization and documentation for cash payments
• Regular cash counts and reconciliations
• Secure storage and handling of cash
• Prohibition of personal use of organizational cash

14. Training and Awareness Programs

14.1 Mandatory Training Requirements

All personnel must complete anti-bribery and anti-corruption training as follows:

• Initial training within 30 days of joining
• Annual refresher training for all employees
• Specialized training for high-risk roles and positions
• Additional training following policy updates
• Management and leadership training on oversight responsibilities

14.2 Training Content and Methods

Training programs include:

• Overview of applicable laws and regulations
• Hospital policy requirements and procedures
• Recognition of corruption risks and red flags
• Case studies and real-world scenarios
• Reporting mechanisms and whistleblower protections
• Consequences of policy violations

14.3 Awareness and Communication

Ongoing awareness initiatives include:

• Regular communication of policy updates and reminders
• Distribution of guidance materials and best practices
• Integration of compliance messaging in routine communications
• Recognition of exemplary ethical conduct
• Open dialogue and feedback mechanisms

14.4 Training Documentation and Compliance

• Maintenance of training records and completion certificates
• Regular assessment of training effectiveness
• Follow-up on incomplete or overdue training
• Integration of training compliance into performance evaluations
• Continuous improvement of training programs

15. Reporting Mechanisms and Whistleblowing

15.1 Reporting Obligations

All personnel have a duty to report suspected violations of this policy or applicable laws. Reports should be made promptly and in good faith through the following channels:

• Direct supervisor or department head
• Human Resources department
• Compliance officer or ethics hotline
• Anonymous reporting systems
• External regulatory authorities when appropriate

15.2 Protection for Whistleblowers

The Smart T Web Hospital is committed to protecting individuals who report violations in good faith:

• No retaliation against good faith reporters
• Confidentiality protection to the extent possible
• Support and assistance during investigation processes
• Anonymous reporting options where legally permissible
• Clear communication of reporting procedures and protections

15.3 Investigation Process

All reports will be investigated promptly, thoroughly, and impartially:

• Initial assessment within 48 hours of receipt
• Formal investigation by trained personnel
• Documentation of findings and recommendations
• Appropriate remedial and disciplinary actions
• Follow-up to ensure effectiveness of corrective measures

16. Investigation Procedures

16.1 Investigation Principles

All suspected violations of this policy will be investigated promptly, thoroughly, and impartially by qualified personnel. Investigations will be conducted with:

• Appropriate confidentiality and discretion
• Fair treatment of all parties involved
• Preservation of relevant evidence and documentation
• Compliance with applicable legal requirements
• Professional conduct and ethical standards

16.2 Investigation Process

The investigation process includes the following steps:

• Initial Assessment: Preliminary review within 48 hours of receipt
• Investigation Planning: Assignment of investigator and development of investigation plan
• Evidence Gathering: Collection and review of relevant documents, interviews, and other evidence
• Analysis and Findings: Evaluation of evidence and determination of findings
• Reporting: Documentation of investigation results and recommendations
• Follow-up: Implementation of corrective actions and monitoring

16.3 Investigation Team

Investigations may be conducted by:

• Internal compliance and audit personnel
• External legal counsel or forensic specialists
• Human resources personnel with appropriate training
• Senior management with no conflicts of interest
• Independent third-party investigators when appropriate

16.4 Rights of Accused Parties

• Notification of allegations when appropriate
• Opportunity to respond and present evidence
• Fair and impartial treatment throughout the process
• Representation by legal counsel when permitted
• Confidentiality protection to the extent possible

17. Disciplinary Actions and Sanctions

17.1 Consequences of Policy Violations

Violations of this Anti-Bribery and Anti-Corruption Policy will result in appropriate disciplinary action, which may include:

• Verbal or Written Warnings: For minor violations or first offenses
• Suspension: Temporary suspension with or without pay
• Demotion: Reduction in position or responsibilities
• Termination: Immediate dismissal from employment
• Contract Termination: Ending business relationships with third parties
• Legal Action: Civil or criminal prosecution where appropriate

17.2 Factors in Determining Sanctions

The severity of disciplinary action will depend on various factors including:

• Nature and severity of the violation
• Intent and level of participation
• Previous disciplinary history
• Position of responsibility and breach of trust
• Impact on hospital reputation and operations
• Cooperation with investigation
• Voluntary disclosure and remediation efforts

17.3 Progressive Discipline

While serious violations may warrant immediate termination, The Smart T Web Hospital generally follows progressive discipline principles:

• First violation: Counseling, training, and written warning
• Second violation: Formal reprimand and disciplinary probation
• Third violation: Suspension or termination
• Serious violations: Immediate termination regardless of history

17.4 Documentation and Records

• All disciplinary actions must be properly documented
• Records maintained in accordance with employment law requirements
• Confidentiality of disciplinary records maintained
• Regular review of disciplinary patterns and trends
• Reporting to regulatory authorities when required

18. Monitoring and Policy Review

18.1 Continuous Monitoring

The Smart T Web Hospital maintains ongoing monitoring of compliance with this policy through:

• Regular internal audits and compliance assessments
• Monitoring of key risk indicators and metrics
• Review of financial transactions and controls
• Assessment of third-party relationships and activities
• Employee surveys and feedback mechanisms
• Benchmarking against industry best practices

18.2 Policy Review and Updates

This policy is reviewed and updated regularly to ensure:

• Compliance with current laws and regulations
• Alignment with industry standards and best practices
• Effectiveness in preventing corruption and bribery
• Incorporation of lessons learned from incidents
• Reflection of organizational changes and growth

18.3 Review Schedule and Process

Policy review follows a structured schedule:

• Annual Review: Comprehensive review of entire policy
• Quarterly Updates: Review of specific sections as needed
• Ad Hoc Updates: Immediate updates for legal or regulatory changes
• Stakeholder Input: Feedback from employees, management, and external advisors
• Board Approval: Senior management and board oversight of major changes

18.4 Performance Metrics

• Number and types of violations reported and investigated
• Training completion rates and effectiveness measures
• Third-party compliance assessment results
• Internal audit findings and remediation status
• Employee awareness and culture survey results
• Regulatory compliance and inspection outcomes

19. Communication and Implementation

19.1 Policy Communication

This policy is communicated to all relevant stakeholders through multiple channels:

• Employee Handbook: Integration into standard employee documentation
• Orientation Programs: Inclusion in new employee and contractor orientation
• Training Sessions: Dedicated training programs and workshops
• Digital Platforms: Distribution via email, intranet, and mobile applications
• Printed Materials: Posters, brochures, and reference guides
• Management Communications: Regular updates from leadership team

19.2 Implementation Strategy

Successful implementation of this policy requires:

• Leadership Commitment: Visible support and modeling by senior management
• Resource Allocation: Adequate staffing, budget, and technology support
• Process Integration: Embedding compliance into business processes
• Culture Development: Fostering an ethical culture and values-based decision making
• Accountability Mechanisms: Clear roles, responsibilities, and performance metrics

19.3 Stakeholder Engagement

Implementation involves active engagement with:

• All hospital employees and medical staff
• Board members and governance committees
• Third-party partners and vendors
• Patients and community stakeholders
• Regulatory bodies and oversight agencies
• Professional associations and industry peers

19.4 Continuous Improvement

• Regular assessment of implementation effectiveness
• Collection and analysis of stakeholder feedback
• Benchmarking against industry best practices
• Incorporation of emerging risks and regulatory changes
• Innovation in compliance tools and technologies
• Sharing of lessons learned and best practices

20. Contact Information and Reporting

For questions about this policy or to report suspected violations, please contact:

This Anti-Bribery and Anti-Corruption Policy is effective as of October 12, 2025. Regular updates will be made to ensure continued compliance with evolving legal requirements and best practices in healthcare governance. All personnel are expected to acknowledge receipt and understanding of this policy and to comply with its requirements at all times.