EMPLOYEE HANDBOOK

CLiCK tO NAvigAtE

Serious about health. Passionate about care.

iNtErNAL usE ONLY

CONtENts

Welcome 3About this handbook 4

Section 1 the company 51.1 About BMi Healthcare 51.2 Our business today 6-7Section 2 Your working environment 82.1 Managing diversity 82.2 Protecting your health and safety 82.3 Notifiable diseases 82.4 substance abuse 92.5 smoking 92.6 What you wear 92.7 2.7 @Work 92.8 Professional qualifications 102.9 Manatory training 102.10 Learning and development 10Section 3 Pay and reward 113.1 Your salary and deductions 113.2 Pension arrangements 113.3 Your place of work 113.4 Business expenses 123.5 Your holidays 123.6 Absence from work 133.7 if you are unwell 14

Section 4 Protecting our reputation 154.1 risk management framework 154.2 risk minimisation stratagies 16-174.3 information security 184.4 Data protection 194.5 Personal use of it resources 204.6 intellectual property and inventions 204.7 gifts and entertainment 204.8 Additional employment 204.9 Protecting confidentiality 214.10 information management 224.11 Handling press enquiries 234.12 security 234.13 stop and search 23Section 5 resolving issues 245.1 grievance procedure 245.2 Disciplinary procedure 245.3 Bullying and harassment 255.4 Whistleblowing 25Section 6 Leaving the company 266.1 retirement 266.2 giving notice 266.3 returning company property 276.4 After you have left 27

A welcome from Jill Watts, Group Chief Executive

Dear Colleague,

i am delighted to welcome you to BMi Healthcare, the private hospital arm of general Healthcare group. You are joining the premier private healthcare provider in the country, with some 59 hospitals across the uK, and i very much hope you will enjoy working with us.

We are tremendously proud of the quality and standards of care that our business delivers. Quality is the foundation of our brand and our patient satisfaction records are second to none. We are serious about health and passionate about care. We hope that you will be proud to be part of our dedicated team.

The efficiency with which we run our business enables us to reinvest each year in leading-edge medical equipment and upgrading our hospitals’ facilities. We are also committed to investing in our people and ‘Building the Best’ by offering them opportunities for training and career development.

All of our training initiatives are aimed at enhancing the quality of the patient care and customer service that we offer, further consolidating our position as a market leader. i hope that, over time, you will be able to take advantage of the career opportunities that BMi Healthcare offers you.

As a company, we look to have a positive influence on society, not only in the field of healthcare but as a responsible business. We strive to minimise our impact on the environment by conserving our resources and reducing waste, and we actively encourage our teams to cut down on unnecessary wastage of consumables, energy and water. Even small changes can make a big difference, and i hope that you will help us to lead in this as well.

Inside this handbook, you will find information about the history of the company, and our policies and procedures. Please read it carefully and contact the Hr Administration team if you have any queries - email: hradmin@bmihealthcare.co.uk

You are very warmly welcomed into the BMi Healthcare family. Yours sincerely,

Jill Watts, Group Chief Executive BMI Healthcare

ABOut tHis HANDBOOK

the purpose of this handbook is to help you to build your understanding of what you can expect from BMi Healthcare as your employer, and equally what we expect from you in return. BMi Healthcare values its reputation for integrity and professionalism, and therefore it is important that you always conduct yourself in the spirit of the policies and procedures set out in this guide. Failure to comply with these policies and procedures will constitute grounds for disciplinary action, which could ultimately result in your dismissal.Full details of all the policies in this handbook can be found on the BMi intranet site. However, if you are unable to access this site, or if you have any queries regarding any of the policies, you should speak to your line manager or the Hr Administration team.

SECTION 1 ABOut BMi HEALtHCArE

London & regional with c7.5%. the balance (c6.7%) is held by management and senior staff.

Between 2007 and 2010, BMi Healthcare grew through acquisition, purchasing over 20 hospitals across the uK. since then, BMi Healthcare has focused on incorporating these sites into the BMi Healthcare network and maximising their capability.

BMi Healthcare’s primary focus has always been treating private patients, and it enjoys strong relationships with all major healthcare insurers. BMi Healthcare has also become a dynamic partner of the NHs and is one of the major independent sector providers of surgical services under the NHs Choose and Book programme.

1.1 Our History

BMi Healthcare’s parent company, general Healthcare group, was founded in 1969 under American ownership (using the name AMi) with the purchase of the Harley street Clinic in Central London. By 1989, there were 13 hospitals in the group. Compagnie generale Des Eaux, the French utilities and service group acquired great Northern Hospitals in 1989, and AMi’s hospitals in 1990. it was at this stage that the Comapny changed its name to general Healthcare group (gHg).

in April 2006, gHg was acquired by a consortium led jointly by Netcare Limited, a south African healthcare company listed on the Johannesburg securities Exchange (JsE) and the private equity company Apax Partners for £2.3 billion on an enterprise value basis. today the consortium consists of the group’s principal shareholders – Netcare with c53.7%, Apax Partners with c32.1%, and

1 ABOuT BMI HEAlTHCArE

1.2 Our business today

BMi Healthcare is the uK’s premier private healthcare provider, with acute care private patient hospitals and outpatient centres at over 59 locations around the country and over 2,700 beds.

BMi Healthcare hospitals have an enviable reputation for providing excellent medical and surgical facilities, supported by state-of-the-art equipment and a high standard of nursing care, within pleasant and comfortable surroundings. Our patients are central to everything that we do and all of our hospitals offer a clean, safe environment where we deliver high quality treatment and services, focusing on:

nn Cleanliness

nn Comfort

nn Care

Equipped with the latest technology, BMi Healthcare hospitals perform more complex surgery than any other independent private healthcare provider in the country. Handling over 276,000 inpatient and 1,500,000 outpatient visits each year, nearly half the procedures undertaken for patients are of a major or complex nature.

BMi hospitals attract consultants from a wide range of specialties, most of whom have extensive experience gained within the NHs. supported by BMi Healthcare’s high calibre staff, they are able to undertake a wide range of procedures from routine investigations to the most complex, high acuity cases such as cardiac and neurosurgery. We are serious about health and passionate about care.

BMi Healthcare consistently outperforms its competitors in patient satisfaction surveys with over 97% of patients describing the care we provide as excellent or very good.* We recognise that maintaining our high standards is critical and requires consistent focus on:

nn Clinical governance

nn Zero infection rates

nn training for our staff

nn High standards of customer service, both clinical and non-clinical

BMi Healthcare has direct billing and settlement arrangements with all of the major private medical insurers. With its wide geographic spread, BMi Healthcare hospitals reach a higher proportion of the population that has medical insurance than any other similar business.* source – independent survey by Howard Warwick Associates

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London

01

20

28

38

08

55

162921

3047

04

0502

25

26

51

53

35

40

48

1103

50

2422 18

56

423252

59

15

41

23 46

33

6017 37

London

58

54

13

43 06

34

1436

10

44

49

45

0761

39 12

2709

5731

19

This version published November 2014 supersedes all previous editions.

1.3 Our business today

1 ABOuT BMI HEAlTHCArE

London & greater London

consultant specialists6,500+

employeesc.9,500

inpatient visits per year276,000

beds2,700

outpatient visits per year

1,500,000

hospitals and clinics across the country

59

H

1 Based on a sample of 57,843 patients completing a questionnaire over the period January – December 2013. Questionnaires analysed by Quality Health, who are an independent survey provider.

2 Based on uK PMi penetration within a 90 minute drivetime of a BMi Healthcare hospital.

97.0rated our overall quality of care as very good or excellent1

different specialties and servic

es

115

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SECTION 2 YOur WOrKiNg ENvirONMENt

2.1 Managing diversity

BMi Healthcare is committed to promoting equality and diversity, and recognises the contribution that each of its employees makes to the success of the business. We aim to end discrimination and promote equality of opportunity for all staff, and we expect everyone who works for us to abide by these principles.

We treat employees with respect at all stages of their employment and do not tolerate unlawful or unfair discrimination on grounds of gender, race, disability, colour, ethnic or national origin, sexual orientation, marital status, responsibility for dependants, political or religious belief, trade union activity or age.

2.2 Protecting your health and safety

We are committed to ensuring the health, safety and welfare of our employees and customers and to providing and maintaining safe working conditions. All employees have a responsibility to take care of themselves, their colleagues and any others within their working environment. they must draw attention to any potential hazards and take part in Company safety drills and training.

Every employee must immediately report any accident, injury or near miss in which they have been involved, in line with Company accident reporting procedures.

2.3 Notifiable diseases

in the event of you becoming or suspecting that you are Hiv, Hepatitis A, B or C positive, or contracting another notifiable disease you must inform your manager immediately. You must also comply with other appropriate tests/procedures for blood borne diseases.

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2.6 What you wear

Where Company uniforms are provided they must be worn, and it is your responsibility to take care of the clothing provided. in the interests of preventing infection, uniforms should not be worn outside the hospital by nursing, paramedics, catering or housekeeping staff. Watches and jewellery may not be worn where they may present a risk to infection control procedures e.g. by preventing effective hand-washing.

Employees who are not required to wear a uniform are expected to dress in a manner that is suitable to their job function and the environment in whichthey work. Managers in each area are responsible for setting and maintaining standards appropriate to the area and function.

in the interests of patient care, all employees at hospitals must wear name badges whilst on the premises for identification and security purposes, except where specified by hospital management for reasons of safety. If your badge becomes damaged, or you lose it, you should obtain a replacement as soon as possible.

2.7 @Work

BMi Healthcare operates an electronic time and attendance system. All staff are required to log in and out at the start and end of their shift, using the @Work terminals that are located at each site. this ensures that staff are paid consistently and accurately for their hours worked. if you forget to log in or out you must report this to your line manager as soon as possible. Persistently omitting to log in or out could lead to disciplinary action, which may in turn result in your dismissal.

2 YOur WOrkING ENvIrONMENT

2.4 Substance abuse

the possession, use, distribution or sale of solvents or unprescribed drugs on Company premises is strictly prohibited. Whilst at work you must not be under the influence of, or incapable of performing your work to a satisfactory standard because of alcohol, non medical-related drugs or other substances.

If it is suspected that you are under the influence of any substance, the matter will be investigated thoroughly and may lead to disciplinary action, which could in turn lead to your dismissal. in addition, the use, sale or distribution of illegal substances is considered to be gross misconduct and, if proved, would also lead to your dismissal without notice or pay in lieu of notice.

if employees are experiencing problems at work as a result of substance abuse, we aim to treat them sympathetically and offer support wherever we can.

2.5 Smoking

Smoking is prohibited in all Company premises.

Quit is a uK charity that helps people to give up smoking. they have a freephone help line called Quitline which can be contacted on 0800 002 200 or, alternatively, their website at www.quit.org.uk contains useful information and advice.

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2 YOur WOrkING ENvIrONMENT

2.8 Professional qualifications

All staff whose employment is conditional upon being professionally qualified are required to keep the appropriate qualifications and registration up to date. Failure to maintain such qualifications and registration may lead to disciplinary action, which could result in dismissal.

Any breach of a professional code of practice will be regarded as a disciplinary matter. You must inform the Company if you become the subject of an investigation by a regulatory body, regardless of whether this is during your employment or after your employment has terminated.

2.9 Mandatory training

to ensure that BMi Healthcare complies with its legal and professional responsibilities all staff are required to keep up to date with their statutory and mandatory training as stipulated in the Mandatory training Framework. Failure to complete mandatory training within the required timescale may result in disciplinary action, which could lead to dismissal.

2.10 learning and development

BMi Healthcare recognises that effective learning and development offers a range of benefits both to employees and the Company. These benefits include:

nn increased motivation and job satisfaction.

nn Higher standard of work performance.

nn greater understanding and appreciation of factors affecting work performance.

nn sharing of ideas and dissemination of good practice.

nn Effective management and implementation of change.

nn Encouragement of team spirit.

nn greater understanding of the BMi Healthcare business.

All permanent clinical employees are trained in the safe use of diagnostic and therapeutic equipment appropriate to their role.

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SECTION 3 PAY AND rEWArD

3.1 Your salary and deductions

salaries are normally reviewed on an annual basis. All increases are discretionary, and any changes will be confirmed to you in writing.

individuals who are suspended from work, undergoing disciplinary action or performance management and anyone who has resigned or is under notice of dismissal will not normally be eligible for a salary increase.

Your salary will be paid monthly on or before the last working day of each month, after any necessary deductions for income tax, National insurance contributions and any other authorised deductions have been made. BMi Healthcare reserves the right to deduct any overpayment from any money owing to you. Where the amount of money is insufficient to cover overpayment, you will be expected to refund the difference.

3.2 Pension arrangements

Making a proper pension provision helps to ensure a safer financial future for you and your family. The BMI Healthcare staff Pension scheme is provided by Friends Life and is not contracted out of the state second Pension (s2P). the employer and employee contributions appropriate to you will be detailed in your contract of employment.

Full details of the scheme can be found in the BMi Healthcare staff Pension scheme Members’ Booklet.

3.3 Your place of work

In order to manage costs and maintain flexibility within our business, it may sometimes be necessary to require people to change the location in which they work. it is therefore a condition of your employment with BMi Healthcare that you may be transferred to a different workplace from the one at which you are initially located on either a permanent or temporary basis.

We will always give consideration to your personal and domestic circumstances, and discuss these with you fully prior to imposing any change of workplace.

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Your annual holiday entitlement is stated in your offer of employment. this entitlement will increase with length of service, with any increases taking effect at the start of the holiday year following the service anniversary. in addition to Bank Holidays, the annual leave entitlement for full time staff is as follows:

Start 25 days

After two years 26 days

After four years 27 days

After six years 28 days

After eight years 29 days

After ten years 30 days

if your initial holiday entitlement is greater than 25 days, any increases will take place in line with the above scale. For example if your initial holiday entitlement is 28 days, it will not increase until you have carried out eight years’ service.

When you leave the Company, your holiday entitlement will be calculated as one twelfth of your full annual entitlement for each complete month that you work in that holiday year. if, due to operational requirements, you are unable to use your holiday entitlement prior to leaving, payment in lieu of the outstanding holiday will be made. However, if you have taken more holiday than you are entitled to, based on your date of leaving, a deduction will be made for these days from your final salary.

if you are ill during any period of annual holiday, this will normally be regarded as part of your annual holiday, not as sickness absence.

BMi Healthcare may require you to take any outstanding holiday during any notice period or period of garden leave.

3 PAY ANd rEWArd

3.4 Business expenses

Any reasonable expenses that you incur in carrying out your official duties will be refunded by the Company, provided they are appropriate and have been previously agreed by your Head of Department. Claims for expenses should be made on a monthly basis and must be accompanied by all relevant original receipts.

3.5 Your holidays

All holiday must be taken to meet business needs, and you must agree suitable dates with your Head of Department prior to confirming any holiday arrangements. You will not normally be permitted to take more than two weeks holiday at any one time, but this requirement may be waived in exceptional circumstances, with the prior agreement of your Head of Department.

the Company holiday year runs from 1 October to 30 september. Any unused holiday will lapse at the end of the holiday year and may not be carried forward or paid in lieu.

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3 PAY ANd rEWArd

3.6 Absence from work

You are expected to attend for work at the agreed time, unless you have obtained prior permission from your manager. if unforeseen circumstances (e.g. sickness, injury or domestic incident) prevent you from attending work, you must inform your manager as soon as possible. it is vital that you follow these procedures to enable our business to function safely and effectively. Persistent poor timekeeping and absence without permission/explanation will be dealt with under the disciplinary procedure (misconduct), which could result in your dismissal.

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3 PAY ANd rEWArd

3.7 If you are unwell

if you are unable to attend work as a result of illness or injury you must notify your manager as soon as possible, and always within one hour of the time at which you were due to start work. You must speak to your manager (or nominated deputy) in person – a text message or email is not acceptable. When you speak to your manager, you should inform them of the nature of your illness, and for how long you anticipate being absent.

On your return to work, you must complete the Company’s self-certification form. If your absence is for more than seven consecutive days, a Medical Certificate will also be required. the Company reserves the right to require the production of a medical certificate for any period of absence at any stage during the absence.

During your absence your manager or an Occupational Health Advisor may visit you. You may also be asked to submit to an examination by a medical practitioner of the Company’s choice either during your absence or before being allowed to resume your duties, and you are required to co-operate with such an examination.

if you are absent by reason of circumstances where you have a claim for compensation against a third party and you recover compensation for loss of earnings from that third party, or otherwise, you will repay a sum equal to the amount recovered or, if less, any amounts paid to you by the Company during your absence.

there is no automatic eligibility for Company sick pay. Payment, other than statutory sick Pay, is granted at the discretion of the Company.

As a guide, subject to following notification and certification procedures, payment for sickness absence may be made as follows during any rolling period of twelve consecutive months. (See table on the right.)

if you are still ill after you have received the maximum amount of paid sick leave, and your rolling 12 month period has ended, you will not be entitled to any further salary or sick pay until you have returned to work for a minimum of three months. Company sick pay will include any eligibility for statutory sick Pay. if the Company cannot authorise statutory sick Pay, an appropriate deduction from your Company sick pay will be made.

Service Eligibility for paid sick leave

0-12 weeks on 1st day of sickness

Nil

13-52 weeks hours on the 1st day of sickness

2/52 of annual hours (2 weeks)

53 -156 weeks hours on the 1st day of sickness

4/52 of annual (hours 4 weeks)

157 - 260 weeks hours on the 1st day of sickness

6/52 of annual hours (6 weeks)

260 weeks + hours on the 1st day of sickness

13/52 of annual hours (13 weeks)

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SECTION 4 PrOtECtiNg Our rEPutAtiON

4.1 risk Management Framework

BMi Healthcare’s commitment to risk management

nn We will comply with all applicable legislation and regulation

nn We will aim to reduce and where possible eliminate risk from the company

nn We will ensure that the minimisation of risk is a key priority at all levels of the business

nn We will undertake risk management activities to control risks to the business, the environment and individuals

nn We will provide our people with the skills and tools to monitor and review our performance

nn We will foster a culture that empowers everyone to minimise risk

BMi Healthcare is committed to establishing an organisational culture that ensures risk management is an integral part of its objectives, plans and management systems.

As a responsible healthcare provider we acknowledge our corporate responsibility to recognise risk management as a core business activity. We have adopted a systems approach to risk management. this approach focuses on the systems in place in which the employee works rather than focusing on the acts or omissions of individual employees.

Because of the inherent risks associated with being a patient in the health care system a key part of the framework is Clinical governance and ensuring that every effort is made to reduce the likelihood and consequence of an adverse event or outcome associated with treatment of a patient.

BMi Healthcare is committed to the health and safety of its employees and all persons who visit our workplaces, or access our services.

in this regard we believe that most injuries and industry related diseases are preventable, and that striving continuously to improve our health, safety and environmental performance is fundamental to our business success.

Every person within BMI Healthcare has a significant role to play in minimising, identifying and reporting potential risk. While this bottom up approach to risk management is critical to the success of any risk management strategy, responsibility for the minimisation of risk is vested with the Executive Board which are responsible to the Board for ensuring effective risk management across the group.

COrPOrAtE gOvErNANCE The Group Chief Executive Officer of BMI Healthcare is responsible to ensure that an effective risk Management framework exists across the group and that the Board are kept informed of the risk status of the business that they are aware of any significant risks to the company.

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4. PrOTECTING Our rEPuTATION

4.2 risk Minimisation Strategies

A brief outline of strategies used to reduce risk within the group is outlined below.

nn Auditing Programmes

to ensure that the company discharges its legal and moral obligations a comprehensive audit programme has been established. the programme includes both internal and external audit function. the internal audit programme is focused around ensuring that all sites and departments follow key policy directions and meet legislative requirements.

the external audit function is conducted by independent external auditors. Our external auditors perform procedures to obtain audit evidence about the amounts and disclosures in the financial statements and the risk systems that are in place across the business.

nn Licensing / registration

BMi Healthcare is required to meet the ever growing requirements of independent bodies that regulate all health care facilities. Bodies such as the CQC regularly inspect our facilities to ensure we meet the statutory and regulatory requirements to ensure the quality of treatment and safety of patients.

nn Credentialing and Practising and Admitting Privileges

to ensure that we have a competent workforce and appropriately trained professionals, BMi Healthcare has clear guidance within its Clinical governance and recruitment polices. All health care professionals are subject to professional and competency review prior to appointment and on an ongoing basis.

nn Policies, Procedures & guidelines

Comprehensive policies and procedures are in place at both the group and Hospital level to provide sound corporate governance and provide guidelines for the safe delivery of health care services.

nn Health, safety and infection Control Programme

Comprehensive Health and safety and infection Control Programmes are in place. these programmes include comprehensive education and auditing processes to ensure that standards are maintained. Mandatory training programmes and checklists ensure that staff are aware of their own obligations in relation to health, safety and infection control issues in the workplace.

nn Clinical indicators

A comprehensive range of clinical indicators are collected and variances analysed at unit and group level.

nn incident reporting

All incidents are recorded, trended and reviewed regularly at a national regional and local level through the committee structure.

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4. PrOTECTING Our rEPuTATION

4.2 risk Minimsation Stratagies

nn Complaints & Claims

Complaints and claims are used as another way of identifying an incident in the delivery of services or clinical care.

nn risk screening

A range of risk screening indicators have been built into the patient pathway to flag patients who are at risk.

nn Patient satisfaction surveys

Patient satisfaction surveys are used in conjunction with performance/clinical indicators to appraise and track company performance.

nn staff and Consultant Feedback

staff & Consultant perceptions and feedback about company risk can inform safety initiatives. staff surveys are also a tool that can be used to assess technical aspects of health care delivery that relate to patient safety.

nn risk register

The Risk Register identifies key risks at a national and local level, and the relevant committee responsible for the on-going management of that risk. Key actions to minimise risk are built into our operational plans.

nn Education and training

A comprehensive education and training programme ia in place to ensure that managers are able to fully discharge their responsibilities.

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4. PrOTECTING Our rEPuTATION

4.3 Information security

information is vital to the way that BMi Healthcare conducts its business. As the controller of a large volume of valuable information, much of which is highly sensitive, BMi Healthcare has a legal, ethical and corporate responsibility to protect that information from unauthorised modification, loss or disclosure, (whether accidental or deliberate).

BMi Healthcare takes its information security obligations very seriously and is certified to ISO/IEC 27001:2005, the international standard for information security management.

An information security Management system (isMs) is in operation that governs policy, acceptable usage and guidance for employees to ensure that information, be it patient, personal or corporate information, is protected against breaches to its confidentiality, integrity or availability.

this includes, but is not limited to:

nn it systems security

nn Electronic communications

nn Email usage

nn internet usage

nn system monitoring

nn Mobile working

nn reporting and investigation of security incidents

nn information security training and awareness

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4. PrOTECTING Our rEPuTATION

4.4 data protection

During your employment, you must comply with BMi Healthcare’s policies and procedures relating to data protection legislation. this deals with the way that personal information is held and used for our patients and employees.

During the course of our activities we will process personal data about our staff, and we recognise the need to read it in an appropriate and lawful manner, and in accordance with date protection legislation. the following paragraphs set out how we handle your personal data

We need to hold a certain amount of basic information about all our employees in order to ensure the efficient running of our business. the information that you provide to us on your application form will form the basis of your employment record and will be processed in line with the principles of the Data Protection Act 1988. You have the right to request and receive a copy of information relating to yourself that is held on our systems. Where necessary, we may use payroll or other information for the purpose of preventing fraud.

in any other cases we will process your personal data only where you have given consent or where it is necessary to comply with our legal obligations or for any of the conditions set out in the Data Protection Act 1998.

the type of information that we need to hold will include (but is not limited to) your home address, emergency contact details (in case you have an accident at work), your bank account details and your National insurance number (so that we can ensure you are paid correctly). it is important that all of the data we hold is accurate and up to date, so you must ensure that you notify your line manager of any changes to your personal details, including your home address, next of kin or any disability or health issue that requires a reasonable adjustment to be made.

We will also need to hold personal data consisting of information as to:

YOur PrOFiLE We hold information on your gender, age, ethnic origin, and disability (if you have one). this data will be used to enable us to monitor trends and promote equality and diversity within our workforce.

YOur PHYsiCAL Or MENtAL HEALtH Or CONDitiON this data may include medical reports on your health and is used to ensure that sickness absence can be monitored and managed effectively, including the production of management information to monitor trends and payment of statutory sick Pay (ssP) where applicable. it is also used to monitor trends in the cause and length of sickness absence, statistics on disability and to help us to promote equality and diversity in the workplace.

DAtA rELAtiNg tO CriMiNAL rECOrDs the nature of our business means that many roles are exempt from the provisions of the rehabilitation of Offenders Act, 1974 and require full disclosure in line with the process operated through the. Disclosure and Barring services (DBs) and Disclosure scotland.

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4.7 Gifts and entertainment

Every employee is expected to observe the highest legal and ethical standards in carrying out their role, and to avoid any actual or perceived conflicts of interest. The integrity of our employees as individuals should earn the trust and respect of both colleagues and patients.

You may therefore not accept any gift (whether tangible or intangible) or corporate hospitality where it is given with the intent to be influenced or rewarded in connection with our business. Acceptance of any gift or hospitality must always be at an appropriate level and authorised by your line manager.

4.8 Additional employment

if you want to take on additional work outside BMi Healthcare, you must obtain the permission of your Head of Department. such permission will not normally be refused, but we would want to ensure that the work would not interfere with your commitments to the Company and that you were not working in excess of the maximum weekly hours set out in the Working time regulations.

4. PrOTECTING Our rEPuTATION

4.5 Personal use of IT resources

You may use the Company’s internet, email and other it resources for reasonable personal use during your break times, provided that this does not interfere with your duties or breach any of the Company’s it or other policies. You must be careful to ensure that you do not view or send any material that might be offensive to others.

As the Company monitors its systems, you should be aware that any emails or other messages you send to or from work may be viewed by others.

4.6 Intellectual property and inventions

it is possible that in the course of your employment you will design, discover or create something that could be protected under intellectual property law.

if you do make such a discovery in connection with your work, your discovery will be owned by the Company and the Company may wish to apply for a patent or other protection to safeguard it. in such circumstances, you must assist the Company in whatever way is necessary, both to protect your discovery and to confirm the Company’s ownership of it.

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This does not apply to confidential information that:

nn may be lawfully disclosed, used or exploited;

nn you are required to disclose by law or by any regulatory authority;

nn has become (otherwise than through your actions) available to the public generally; or

nn the Company has granted permission to disclose.

in addition, you must not, (except in the proper course of your duties) without the consent of the Company:

nn publish any opinion, fact or material;

nn participate in the making of any film, radio, television, worldwide web or other media broadcast or transmission; or

nn communicate with any representative of the media;

in connection with any issue that comprises or concerns confidential information, or so as to reveal any confidential information belonging to the Company.

4. PrOTECTING Our rEPuTATION

4.9 Protecting confidentiality

the nature of our business is such that during the course of your employment, you are likely to create, have access to, be entrusted with, or come across confidential information concerning either patients, customers, suppliers or financial information relating to the Company. The unauthorised use or disclosure of confidential information could be damaging to the Company, and therefore you must not, either during your employment or after it has ended:

nn use or exploit confidential information for your own or another person’s benefit;

nn disclose confidential information to any person who has no right to see or have it; or

nn fail to exercise reasonable care so as to cause or permit the unauthorised use or disclosure of confidential information.

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4. PrOTECTING Our rEPuTATION

4.10 Information management

information is a vital asset, both in terms of the healthcare management of individual patients and the efficient management of internal and contracted services and resources. BMi Healthcare is committed to ensuring that all records and information are dealt with legally, securely and effectively.

All members of staff, contractors or consultants who have access to confidential information are bound by contracts of employment or confidentiality agreements and common law to maintain confidentiality, both during the time they are working for BMi and after that period has ended.

Another person’s password must not be used to gain access to information under any circumstances, or to attempt to gain access to any part of the system or information that is not allowed by their access privileges.

training on the uK Data Protection Act and Caldicott Principles will be provided to ensure that members of staff understand their responsibilities in managing information appropriately within the business unit processes and daily working practices.

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4.12 Security

BMi Healthcare aims to ensure that all employees understand their security responsibilities, and act with honesty and integrity at all times. this includes:

nn Addressing security responsibilities prior to employment in line with the identified security screening requirements appropriate to their role and in accordance with their terms and conditions of employment.

nn screening all candidates selected for employment as an integral part of the recruitment process, and requiring third party suppliers and contractors to undergo equivalent screening.

BMi Healthcare will ensure that employees are aware of information security threats and concerns, their responsibilities and liabilities, and are equipped to comply with BMi Healthcare information security policies in the course of their normal work.

4.13 Stop and search

the Company retains the right to search any employee’s purse, bag, parcel, vehicle, or other property on, or when leaving, Company premises.

in exceptional circumstances, where it is considered that an item may have been concealed about the employee’s person, the police may be called to conduct a full body search. this would be conducted by a person of the same sex, with a third party in attendance.

Any searches will be carried out on a random basis and will not discriminate between different levels or groups of staff. Any inspection of personal property will be carried out by management and/or security staff in a private area.

4. PrOTECTING Our rEPuTATION

4.11 Handling press enquiries

if you receive any enquiries from the media e.g. press, radio or television, you should refer the matter to the Public Relations team at Head Office. No interviews should be given on any matter concerning the affairs of the Company or our individual hospitals without the prior approval of the National Director of Pr and Marketing.

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SECTION 5 rEsOLviNg issuEs

5.1 Grievance procedure

grievances are concerns, problems or complaints. Like all problems, grievances are best resolved if they are acted upon quickly. Wherever possible, you should try to resolve any problems through informal discussion with your line manager or Human resources. if this doesn’t work, you can use the formal grievance procedure.

Full details of the grievance Procedure can be found on the BMi Healthcare intranet, and are summarised in the booklet Quick reference guide to problem-solving at work – discipline, grievance and appeals.

5.2 disciplinary procedure

From time to time, a disciplinary issue may arise when a problem of conduct or capability is identified. We will always attempt to resolve issues informally but if this is not possible, managers will seek to address the issue by way of a fair procedure.

Full details of the Disciplinary Procedure can be found on the BMi Healthcare intranet, and are summarised in the booklet Quick reference guide to problem-solving at work – discipline, grievance and appeals.

Neither the Disciplinary nor the grievance Procedure form part of your contract of employment, and are therefore not contractually binding on either you or the Company.

SECTION 5

that any of the following actions have been, are being or are likely to be committed:

nn financial fraud;

nn a criminal offence;

nn a miscarriage of justice;

nn an act creating risk to health and safety;

nn an act causing damage to the environment;

nn a breach of any other legal obligation; or

nn concealment of any of the above;

it is not necessary for you to have proof that such an act is being, has been, or is likely to be committed – a reasonable and genuine belief that this is the case is sufficient.

Anyone who makes such a protected disclosure has the right not to be dismissed or subjected to victimisation because they have made the disclosure.

if you are not sure whether to raise a concern, you should discuss the issue (in confidence) with your line manager or your regional Hr Business Partner.

5 rESOlvING ISSuES

5.3 Bullying and harassment

BMi Healthcare is committed to providing a healthy working environment where all staff are treated with the dignity and respect they deserve. We do not tolerate bullying, harassment or any form of unwanted behaviour and will deal with any allegations of such behaviour in line with the Disciplinary Policy.

5.4 Whistleblowing

it is important that any fraud, misconduct or wrongdoing by workers or officers of the Company, is reported and dealt with properly. the Company therefore has a documented procedure to enable you to report (in confidence) any instances where you genuinely believe

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SECTION 6 LEAviNg tHE COMPANY

6.1 retirement

The Company currently has no fixed retirement age, although this will be reviewed from time to time to reflect our business needs. We acknowledge that retirement is a matter of choice for individuals and we will not pressurise staff into resigning because they have reached or are approaching a certain age.

staff are free to retire whenever they choose or to seek alternative roles or working patterns. For further information please refer to our Flexible Working policy.

the Company is committed to employing people of all ages and consider that age diversity is beneficial to the business. We are committed to not discriminate against staff because of age and adhere to the principles set out in our Equality and Diversity policy.

6.2 Giving notice

the notice periods that you are required to give the Company, and that the Company will give you, are specified in your contract of employment.

the Company reserves the right to make a payment in lieu of all or any part of your notice period.

BMi Healthcare reserves the right at its absolute discretion during all or part of your notice period to prevent you from dealing with or having any contact with any patients, consultants or prospective consultants, employees, suppliers or prospective suppliers, to exclude you from the premises, to require you to carry out specified duties at premises other than your normal place of work, or different duties from those you usually perform. During any such periods you will continue to be paid at your normal rate and your contract of employment will remain in force.

Your employment may also be terminated without notice or pay in lieu of notice if you commit an act of gross misconduct, which may include failure to comply with any of the Policies and Procedures applicable to your employment including those detailed in the this document.

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6 lEAvING THE COMPANY

6.3 returning company property

When your employment ends (regardless of the reason for this) you must immediately return any company property that is in your possession or under your control. this includes (but is not restricted to) your uniform, name badge, security pass, blackberry mobile phone, computer equipment and any other property or documents (whether electronic or paper format).

6.4 After you have left

regardless of your reason for leaving, you will continue to be covered by certain restrictions for 12 months after your leaving date.

You may not, whether directly or indirectly, recruit or try to recruit any person as an employee or consultant or in some other capacity if that person was at any time during the last 6 months of your employment employed by the Company and you had regular contact with him/her through your employment with the Company.

You will not, without the written consent of the company, disclose any trade secret or confidential information concerning the company’s business, finances or affairs, or those of any of its Associated Companies which has come to your knowledge during the course of your employment with the company.

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