Capio's Code of Conduct

Capio’s Code of Conduct guides the principles for the decisions taken by the Group, its Board of Directors and employees within the framework of its activities and in the interaction with its patients, employees, clients, business partners, shareholders and society in general.

The Code of Conduct is built upon the cornerstones of honesty and integrity, and incorporates Capio’s values to be part of the day-to-day activities.

Capio’s employees must adhere to the Code of Conduct, and each manager is responsible for ensuring that employees and busi- ness partners are informed of its content. Employees are required to report any deviations from the Code of Conduct to their mana- gers for investigation and possible corrective action. Compliance with the Code of Conduct is monitored continuously as an integral element of business management. Each manager is responsible for local follow-up and reporting of any relevant issues. Repeated, serious deviations lead to corrective measures.

The Capio Group respects and supports the protection of inter- national human rights within its sphere of influence, and also respects the ILO’s conventions to protect fundamental human rights.

In connection with the updating of Capio’s Code of Conduct in 2013, new policies were also implemented in order to detect and deter cases of bribery or other corruption. The policies are supple- mented with specific guidelines for each of the countries in which Capio operates. Any suspected breach of these policies is to be investigated and any necessary measures are to be taken. All employees within the Capio Group have received detailed informa- tion about the company’s policies for transparency, as well as about the routines and procedures that apply to upholding these standards. 

The information initiative was undertaken in cooperation 

with the European Works Council (EWC) and is followed up at local level. Information can be found at Capio’s website.

During 2013, a whistleblower function was established whereby Capio encourages employees and other persons in contact with Capio’s activities to report any serious wrongdoing they may have encountered, including any illegal actions, conflicts of interest, dubious reporting principles or abuses of power or authority. The function serves as a supplement to the internal reporting system, which means the manager responsible or the human resources department. Any serious wrongdoing by management or other key staff within Capio may be reported on an anonymous basis. Capio’s whistleblower function is handled by an independent law firm in Sweden, and all notifications are investigated.

In 2011, Capio signed a collective agreement with Swedish trade unions that guarantees all Capio staff in Sweden the freedom to disclose information. Any Capio employee is entitled to contact and personally comment or give information to the media, either anonymously or in his or her own name. Capio’s management and managers will not investigate the source of information published in the media. Employees that comment to the media may not be dis- criminated against as a consequence.

The freedom to disclose information was already in practice within the Capio Group and this collective agreement has formali- zed and further clarified the employees’ rights. The agreement gives Capio’s staff in Sweden the same right to disclose informa- tion as public-sector employees, in accordance with the Swedish Public Access to Information and Secrecy Act, with the exception of information that is protected by a duty of confidentiality or the Swedish Act on the Protection of Trade Secrets.