PRH0705 – POLICY/ CODE OF ETHICS AND CONDUCT

DOCUMENT REVIEW/MODIFICATION STATUS
Edition numberDateReason of the review
07th January 2020Initial edition
0101rst September 2023Addition of a channel for complaints
   
DEVELOPED BYIMS ManagerREVIEWED BYGeneral ManagerAPPROVED BYManagement

Name: Fátima Guillén

Date:  01/09/2023

Name: Agathi Kanellou

Date: 01/09/2023

Name: Fátima Guillén

Date: 01/09/2023

  1. OUR MISSION AND VALUES

OUR MISSION

MCI was founded in Madrid in 2002 with the aim of providing medical expense management control and travel healthcare assistance services of the highest quality standards, tailored to the specific needs of insurance companies.

Over the years, MCI has proved the ability to evolve and to adapt to market changes, which has been the key to its success in such a competitive industry as medical assistance. Our extensive experience in the insurance sector and in the healthcare of expatriates and foreigners has given us a unique insight into the individual needs of our clients, enabling us to offer a variety of medical-healthcare management and cost control services.

Throughout the years, we have developed a large portfolio of clients from the corporate sector, assistance companies and insurance companies. We manage highly complex medical cases for various insurance companies thanks to a team of operators, nurses, and doctors available 24 hours a day, providing operational support and clinical advice. The service is provided from facilities located in Madrid with a 24/7 multilingual platform.

Each client has specific requirements that are met from the beginning to the end of the contract in the terms agreed by both parties.

Likewise, transparency and adherence to ethical standards in our work distinguishes us from other companies, and it is highly appreciated by our clients and medical providers. Upholding values of conduct based on integrity and seriousness has led us to work with the most respected companies in the industry, renowned for their excellent reputation.

 

OUR VALUES

MCI actively participates in the insurance market with integrity, strictly observing the prevailing laws. Additionally, MCI establishes ethical and professional behaviour in all its relationships with clients, always safeguarding their interests and those of their insured parties.

Its mission is to offer clients a professional and objective service with the best alternatives in the market, providing personalised and client-focused information that is truthful and as clear and precise as possible.

  1. Independence: independence from any insurance company guarantees the protection of the client. It is essential to maintain and convey our integrity as a company and always look out for our clients’ interests when contracting any service.
  1. Commitment: we distinguish ourselves from other companies in the sector by offering close, accessible, and personalized service, committed with our clients’ interests in all services we offer.
  1. Innovation: for over 15 years, we have provided our clients with innovative, flexible and guaranteed services, employing the latest technologies that guarantee the security and confidentiality of information.
  1. Professionalism and Experience: The training, specialization, and professional ethics are aspects that characterize our team. Our core principles of action are based on information transparency, honesty, and integrity.

Experience has taught us that the continuous training of our employees is vital to being a reference in our business. The complexity of our services requires highly skilled, prepared, and competent professionals who accompany and support our clients throughout the service provision.

  1. Quality: Adopting quality criteria and procedures that optimize internal functioning and ensure maximum client satisfaction is a priority for MCI. To this end, MCI has implemented and is certified under ISO 9001 for Quality Management System. It also embraces new technologies, ensuring their security through ISO 27001 certification.
  1. Compliance and CSR: MCI conducts its activities in accordance with the law and with solid ethical and professional principles, adopting all necessary security measures from design to the value chain to ensure the proper functioning of its business. Placing special importance on the privacy of our clients’ data, we advocate for a proactive protection and treatment model that guarantees the rights of clients and third parties.

Corporate Social Responsibility (CSR) is an essential value for a company like MCI due to its impact of its actions on the insurance market. At MCI, we promote a socially responsible attitude and an environmentally friendly policy within our team and the community. We aim to raise awareness and foster sustainable practices and community support.

  1. OUR CODE

OUR CODE OF CONDUCT

This procedure refers to the Code of Ethics and Conduct (hereinafter, “the Code”) of MEDICAL CLAIMS INTERNATIONAL, S.L., with CIF: B-83436444 and registered office at Santa Leonor 65, Building B, 1st Floor, 28037 – Madrid (hereinafter, “MCI”), and serves as a guide for the conduct of MCI employees, executives, and administrators, both in internal and external relations, to ensure ethical and responsible behaviour in the development of our activities, always in line with our corporate principles and values.

PURPOSE OF THE CODE OF CONDUCT

 

This Code of Conduct reflects the behavioural guidelines to be followed in the development of our professional activities, in accordance with MCI’s mission and principles, and unifies the performance policies, especially those related to the marketing and provision of our services, already implemented by our team.

In this way, the Code highlights the experience we have acquired over the years and reflects MCI’s commitment to continue practising our profession in the most diligent, ethical, and professional manner possible.

Our actions must not only be morally acceptable but also faithful to the spirit of the Law. Therefore, the provisions of this Code must align with the Law, and if any inconsistency is detected, it must be verified and corrected.

Its objective is to promote and encourage ethical and conduct values in line with social responsibility, corporate commitments, and the will to comply with regulations and avoid MCI offences. Thus, aligning the ethical culture as an essential step in the formation, awareness, and development of the Compliance Culture (in terms of promoting, supervising, and monitoring regulatory compliance as well as preventing offences, by promoting ethical standards among MCI staff in the performance of their activities, thereby reinforcing diligence in this matter).

 

SCOPE OF APPLICATION

 

This Code binds all MCI employees, from top management to the rest of the team, as well as the entire value chain of the company.

Each and every one of them is obliged to respect the principles of conduct set out in this Code, committing themselves to comply with the entity’s internal procedures and policies, and to always act in accordance with current legislation. Thus, through their actions, they promote a culture of compliance and the ethical behaviour that MCI expects from everyone in the company.

Therefore, the conduct outlined in this Code applies at all levels of the entity, as well as to third parties with whom MCI interacts.

  1. GENERAL RULES OF CONDUCT

Preserving MCI’s values requires training professionals in the risks they are exposed to and establishing specific guidelines for action. This Code of Ethics and Conduct applies to all day-to-day operations and complements the general rules, guidelines, policies, and internal procedures existing within MCI.

The guidelines, rules, and statements contained in this Code are not static; rather, it is generally expected that MCI professionals will respect external and internal laws and regulations as an unavoidable obligation.

Workers and other individuals affected by this Code must avoid behaviours that, even if not violating legality, contradict the values, principles, and/or ethical behaviours established.

COMMITMENT TO OUR ENVIRONMENT: SOCIAL RESPONSIBILITY AND ENVIRONMENTAL RESPECT.

 

One of MCI’s primary concerns is social responsibility towards the environment, as well as respect for the environment. This means that we are deeply committed to our surroundings.

Our commitment to the environment has led us to establish internal policies, to obtain certification in ISO 14001 for Environmental Management, and to promote actions within the company, such as recycling and digitalizing processes, to promote a culture of sustainability among our employees and partners and thereby minimize the environmental impact of our work activities.

GOOD USE OF ELECTRONIC MEANS OF COMMUNICATIONS

 

Considering that the majority of our activities are carried out through electronic means of communications, MCI, in order to safeguard the protection of its clients, commits to implement internal policies that protect personal data security to the extent possible.

Additionally, alongside our own policies, MCI holds the distinctive seal of ISO 27001 for Information Security. This further reinforces our quality and compliance values, as well as our commitment to promoting self-regulation systems in terms of electronic communication.

Since 2016, MCI has strengthened its commitment to information security through the annual acquisition and revalidation of the ISO 27001 for Information Security.

All recipients of this Code are responsible for ensuring compliance with both internal policies and the proper management of electronic communications.

RESPECT FOR RIGHTS IN THE FIELD OF ADVERTISING

Any communication made in the performance of professional activities aimed at promoting MCI’s services must be conducted with the utmost respect for the values outlined in this Code and in compliance with current legislation.

Specifically, all actions intended for MCI’s dissemination and advertising must ensure that their content is non-discriminatory, guaranteeing respect and integrity and rejecting any unequal treatment based on nationality, race, gender, sexual orientation, religious or political beliefs.

Respect for the right to honour shall prevail, maintaining a proactive attitude aimed at avoiding aggressive practices. Additionally, advertising used through electronic means of communications must scrupulously respect applicable law, exhibiting fair, honest, and truthful content. It shall never serve as a means of abusing the good faith of our clients, and its content must be fully identifiable, prioritizing the principles of comprehension, fidelity, and transparency.

In the performance of our duties, MCI members must especially value the protection of children and adolescents, ensuring that advertising disseminated through websites and social media platforms will not cause moral or physical harm to minors or adolescents. To this end, MCI will carefully monitor the use of presentations that may lead to moral or physical harm or those that may involve images that risk engaging in this illegal activity.

TRANSPARENCY IN COMMERCIAL TRANSACTIONS

All employees, when conducting commercial transactions on behalf of MCI, must demonstrate transparent conduct and attitude, informing the client at all times of the real conditions regarding price, terms, conditions, and payment methods.

In relation to contracts carried out by MCI with its clients through distance electronic means, they shall be preceded by clear and understandable information that accurately reflects the price, terms, conditions, and payment methods of the transaction to be conducted. If there are additional supplements, they shall be clearly and comprehensibly stated.

PROTECTION OF PERSONAL DATA AND PRIVACY

MCI complies with current data protection legislation, respecting the right to privacy and protecting the personal data entrusted by its clients, always acting with due diligence and taking the necessary measures in accordance with Spanish Organic Law 3/2018, of 5th December, on Data Protection and Digital Rights Guarantee (hereinafter referred to as LOPDGDD).

Specifically, since MCI conducts a significant portion of its activities through electronic communication media, all employees are required to exercise maximum accuracy in the event of collecting, processing, or storing personal data.

CUSTOMER SERVICE

 

MCI provides clients with a permanent Customer Service, through which they can make inquiries, complaints, or grievances. Given the importance that MCI places on protecting and caring for its clients, it is crucial that all employees who have access to the information sent during the course of their activities, whether in the form of a complaint or grievance, handle it in accordance with the entity’s privacy and data protection policy and in compliance with applicable legislation.

CONFIDENTIALITY OBLIGATION

Employees shall not disclose or use confidential information related to MCI or its clients with third parties or other employees who are not authorized to access such information.

Additionally, they must apply the current regulations and internal measures for handling all confidential information and documentation, which are considered fundamental assets for the company. This information cannot be used for personal benefit or for purposes contrary to the law.

What information will be considered confidential?

– All business information (financial, legal, commercial, strategic plans, statistics, and others);

– All information provided by third parties in the course of professional activities (employees, providers, and insurance companies, among others);

– All client information – including information about clients’ insured parties.

The duty of confidentiality remains in effect even after the termination of the employment relationship.

INTELLECTUAL PROPERTY AND INDUSTRIAL PROPERTY

In its commitment to fostering a culture of respect for the law, MCI acknowledges the importance of safeguarding Intellectual Property Rights and Industrial Property Rights for legal security and social development.

Therefore, the entire MCI team must commit to respecting not only the company’s rights but also those of third parties.

MCI staff must:

–  Avoid and rectify any conduct that could presumably constitute a violation of these rights;

– In terms of Intellectual Property Rights, special attention will be given to the use of melodies and text or video content with the aim of developing the company’s own works. Third-party consent, authorization, or license must be obtained without exception;

– Concerning MCI’s Industrial and Intellectual Property Rights, the various business lines must ensure the safeguard of ideas, products, methodologies, and strategies, promoting protection through the appropriate patents, registered trademarks, and copyrights if necessary;

– Third-party trademarks will not be exploited for commercial campaigns without their consent.

The above list details the main conduct and attitudes MCI employees must adopt and/or observe. Employees must act at all times to prevent any violation of this precept, even if it is not included in the list.

CONFLICT OF INTEREST

MCI will consider a conflict of interest to be any situation where the entity may gain a benefit that results in a corresponding detriment to a client, or where a client may gain a benefit or avoid a loss at the expense of another client.

Conflicts of interest will also include cases involving personal contracts or transactions by employees, especially if they constitute actions outside the scope of their duties. This also applies to transactions involving family members and/or similar relations.

Any conduct likely to generate a conflict of interest must be immediately reported to the Internal Control Body for resolution.

Among the policies to avoid conflicts of interest that all MCI members must respect, we highlight:

– Employees shall ensure the proper use of MCI’s resources and assets, allocated for the performance of their duties.

– MCI’s management members shall refrain from becoming partners in any supplier company with which services are contracted.

– There shall be mechanisms for the segregation of duties, ensuring that the person handling claims is different from those processing the corresponding indemnity payments.

The above list details the main behaviours and attitudes MCI employees must adopt and/or observe. Employees must act at all times to prevent any violation of this precept, even if not included in the list.

COMPLIANCE WITH TAX OBLIGATIONS

In line with the principles and values of this Code, our employees are required to fully respect and comply with tax obligations.

MCI commits to fulfilling its tax obligations and social security payments, to which it is obliged, responsibly and legally. Employees entrusted with tasks involving the processing of data related to accounting, including the collection of books, records, and financial statements, commit to ensuring that such data accurately reflects the true image of the company.

MCI guarantees that all information entered and recorded in its systems is accurate and complies with all legal requirements. Employees are strictly prohibited from hiding or distorting information in the accounting records or altering or falsifying them.

ANTI-CORRUPTION AND ANTI-BRIBERY POLICIES

MCI is committed to eradicating any form of corruption and influence peddling. Its professionals pledge not to request, accept, or offer any unjustified benefit or advantage of any nature that directly or indirectly favours MCI, the professional themselves, or a third party over others.

Under no circumstances shall MCI employees, executives, or administrators accept any benefit that, due to its value, could be interpreted differently from a mere courtesy gesture, in accordance with applicable regulations in force and the existing practices in society. In case of doubt, the professional should consult with the Internal Control Body’s responsible person.

MCI acknowledges that social courtesy rules vary by country. However, the main thing to consider before accepting any gift, favour, or invitation is that they remain within reason and normality, so as not to surprise or influence our business judgment.

It’s crucial to prohibit bribes in relationships with public entities, meaning no offers, promises, deliveries, or acceptance of any kind of gift or benefit to or from officials or authorities.

Such conduct may result in disciplinary measures by the company, in addition to the legal consequences that such behaviour may entail.

Some examples of unacceptable behaviour by MCI staff in this regard are as follows:

– Accepting or offering gifts to suppliers or insurance companies to establish a professional relationship or influence their commercial judgment.

– Accepting cash, checks, or credit cards.

– Accepting illicit commissions in their relationship with insurance companies.

– Accepting personal favours to secure a professional relationship.

The above list details the main behaviours and attitudes MCI employees must adopt and/or observe. Employees must act at all times to prevent any violation of this precept, even if not included in the list.

COMPANY ASSETS AND COMPUTER SYSTEMS

MCI provides its employees with the necessary resources, including computer tools, to perform their professional duties. It’s essential to highlight that these computer applications are particularly significant given that our activities primarily involve electronic commerce.

Employees are expected to use computer systems and the corporate system responsibly, solely for professional activities. These systems should be used following criteria of security, caution, and efficiency, excluding any misuse, illicit activity, or conduct contrary to MCI’s ethical principles.

Regarding the use of assets and other tools (computers, email, telephone, etc.) provided by the company to employees for carrying out their work activities, employees must make appropriate use of them, as well as the company’s facilities, always for the intended purpose and in accordance with MCI’s corporate purpose, unless expressly authorized; they may not engage in activities contrary to this, such as accessing third-party applications or computer systems without the prior documented authorization of the owner.

The rights of use and exploitation, as well as the ownership of the property of the computer programs and systems (including the website) belong to MCI. Therefore, none of the exploitation rights shall be deemed transferred to users beyond their proper use. Similarly, MCI owns the equipment, manuals, and reports developed by employees in the course of their employment using the company’s computer systems.

Regarding MCI’s corporate online reputation, the company’s digital identity must align with the values and principles outlined in this Code, and conduct related to telematic means that enable online operations must conform to this. Additionally, MCI will ensure that its online business lines effectively reflect the company’s image and will prevent any harmful content to the stakeholders it relates to (insurance companies, providers, users/insured individuals).

Any activity that may affect MCI’s digital identity should be reported to the person responsible for verifying and addressing the issue to minimize potential damages. Through security system modifications and/or the implementation of new security measures, efforts should be made to prevent similar incidents from occurring in the future.

 

PREVENTION OF MONEY LAUNDERING AND TERRORISM FINANCING

MCI is aware of the devastating socio-economic impacts of these criminal practices, especially on economic and financial markets. Thus, MCI is firmly committed to the international and national fight against these activities.

MCI complies with the current regulations on the Prevention of Money Laundering and Terrorism Financing (Spanish Law 10/2010, of 28th April, on the prevention of money laundering and terrorism financing, and Royal Decree 304/2014, of 5th May).

  1. RELATIONS OF INTEREST

CONDUCT WITH THE COMPANY

MCI is committed to establishing all necessary internal controls for the proper functioning of the company. These controls will be periodically verified and modified as needed, always in compliance with the law and to ensure the company’s purposes are met.

CONDUCT WITH EMPLOYEES

Respect for human rights and workers’ rights are guiding principles of MCI’s social responsibility. MCI is committed to ensuring good working conditions for its employees, providing a healthy and safe working environment, and opposing to any form of irregular work, particularly exploitation and child labour.

MCI guarantees equal treatment in hiring, training, and promotion, opposing discrimination based on gender, race, religion, sexual orientation, or political opinion.

Good working conditions and continuous training foster human and professional development and ensure personal dignity. Any form of violent or offensive behaviour against employees’ rights and dignity, including workplace harassment, is rejected.

MCI is committed to establishing social dialogue between senior management and the rest of the staff, ensuring their civil and political rights are respected, promoting employee stability and the proper functioning of the company. The company acknowledges the importance of personal development alongside professional growth and will implement the necessary mechanisms to effectively balance both.

As we have already mentioned, it is important to ensure a good working environment for employees, where essential hygiene, health, and safety standards are met, thus guaranteeing the rights to health and integrity of individuals. This need is addressed through the external hiring of an Occupational Risk Prevention Service, responsible for the development of the corresponding Occupational Risk Prevention Plan, which is made available to MCI members to ensure their awareness.

Finally, employees must behave in accordance with the ethical standards established in this Code, as provided for by law, and act in accordance with their roles within the company. In the event of any infraction, and in accordance with the labour disciplinary regime, the sanctions provided for in the General Insurance Agreement may be imposed, and failing that, the provisions of the Workers’ Statute will apply.

Examples of behaviours to avoid by employees and for which, if applicable, they may be sanctioned:

  • Workplace harassment.
  • Any form of discrimination or disrespectful behaviour towards colleagues or third parties.
  • Engaging in hiring practices that are not equitable and non-discriminatory.
  • Improper use of company assets or property rights that may cause harm to the company.
  • Actions that could damage the company’s image and reputation.
  • Situations generating conflicts of interest.
  • Illegal or unethical behaviour contrary to the principles outlined here.

CONDUCT WITH CLIENTS

Proximity and loyalty to clients are fundamental values in the exercise of our activities. For MCI employees, it is essential to advise our clients, always prioritizing their circumstances and needs. We know that each client is different, and we perform our duties by offering personalized service, allowing our clients to benefit from over 15 years of experience in taking care of them.

Our priority is to answer quickly and effectively to any requests, questions, or concerns our clients may have, providing the appropriate approach to meet their priorities. To this end, MCI is committed to the constant pursuit of quality and excellence, achieving a highly satisfying customer experience. Our position allows us to guarantee personalized service, with complete independence and security for our clients, tailored to their needs and characteristics.

Respecting our principles and values, all MCI employees will focus their efforts not solely to sales but to advising individuals and companies based on their specific previous situations.

COLLABORATION WITH AUTHORITIES

MCI acknowledges the efforts of public administrations and regulatory bodies in ensuring the proper functioning of the market.

For this reason, MCI has emphasized in this Code its commitment to and fight against practices or conducts involving fraud, corruption, money laundering, terrorism financing, or any other conduct contrary to the law. Thus, the entire MCI team is firmly committed to providing maximum cooperation with the authorities.

In particular, our employees will fulfil their duties with the utmost transparency and cooperation in:

– Managing requests from regulators and supervisors.

– Meeting periodic information obligations to regulators and supervisors.

This commitment does not exclude compliance with any other type of requirement.

  1. RESPONSIBILITY FOR CODE COMPLIANCE

 

MCI will foster a high level of commitment among employees to comply with this Code of Ethics and Conduct. MCI will provide the necessary resources to its employees to disseminate and enforce the principles of conduct contained in this Code of Ethics and Conduct. Furthermore, employees are encouraged to proactively propose improvements and raise any questions regarding its interpretation. Any questions an employee might have about the interpretation or application of this Code should be referred to the Head of the Internal Control Body. In this way, this Code will fulfil its objective of becoming a manifesto of everyone’s will.

Possible violations of the Code of Ethics will be solved according to the disciplinary regime provided in the applicable regulations. MCI employees and third parties will confidentially and in good faith report any actions contrary to the Code of Ethics and Conduct that they may observe.

In compliance with Spanish Law 2/2023, of 20th February, regulating the protection of individuals who report regulatory violations and combat corruption, and in accordance with the guidelines outlined in the Code of Ethics, everyone at MCI must act under a standard of integrity and compliance with laws and internal regulations, as well as cooperate to prevent anyone from acting improperly.

To this end, they will use the Whistleblower Channel established by MCI, which allows employees and third parties to confidentially consult doubts and report irregular conduct, whether of a criminal nature or any other type, related to the Code of Ethics and Conduct.

Therefore, we must all report any suspected irregularity or act contrary to legality or internal regulations of which we are aware. Only in this way can any suspicion or doubt of irregularity be checked and, if necessary, appropriate measures be taken to repair its consequences and prevent it from happening again in the future; thereby improving the professional, social, ethical environment, and commitment to compliance with the laws.

MCI formally establishes that it will not tolerate reprisals against those who use the established procedures to report irregular conduct, whether of a criminal nature or any other type, related to the Code of Ethics. The management or corresponding bodies will comply with the requirements provided in the personal data protection legislation regarding the communications submitted by professionals in accordance with the Code of Ethics and Conduct.

  1. DISSEMINATION OF THE ETHICAL CODE.

The Code of Ethics and Conduct will be communicated and disseminated among MCI employees through appropriate means. The external dissemination of the Code of Ethics and Conduct is the responsibility of the Human Resources department.

However, all departments, within their competencies, will contribute to increasing the aforementioned dissemination. To manage the initial communication, an internal and external communication plan will be developed.

  1. APPROVAL AND ENTRY INTO FORCE

 

This Ethical and Conduct Code will enter into force the day after its approval by the Management.

Approved by Management:

_________________________________________

MCI CEO