Real Medicine Foundation's

Policies

Conflict of Interest

All RMF employees and board members are advised that they must declare whether in their view they might have business, commercial or financial holding that could be deemed to be in actual or potential conflict with their current responsibilities. Furthermore whenever any possibility arises of an actual or potential conflict between an employee’s or board member’s financial and commercial or business holding and her/his current responsibilities, it is the responsibility of the employee/ board member concerned to submit a written disclosure.

Dealing with Conflicts of Interest

In our work, conflicts can arise between our personal interests and RMF’s corporate interests or those of our funding partners, project partners, and target groups. We immediately reveal such conflicts of interest to our superior and we resolve them in a manner that is objectively verifiable by and understandable to all parties involved. In our work, conflicts can arise between our personal interest and RMF and we take sufficient care to separate business and private spheres.

Conflict of Interest, Personal and Financial Connections

Should a staff or board member have any connections, be they personal, family related, financial, or of any other nature, to RMF business partners, competitors or their employees, which could impinge on the objectivity of decision making or dealings within the scope of his or her work for RMF, then the respective superior must be informed, hereof, so that s/he can make a decision on the further course of action. If the matter concerns awarding of contracts, the relevant staff or board member is excluded from participating in the decision-making for the award procedure, except in the event that no conflicting interest exist for the person involved or if the activities have no impact on the decision making in the contract awarding procedure.

If a staff or board member is intending to conclude a contract with his/her spouse/cohabiter or any other person to whom the staff or board member is closely connected or related, the staff or board member shall inform his/her superior in order for a pertinent decision to be made. The staff member shall not make a decision him/herself on the conditions of employment or any changes thereto.

Separation of Business and Private Spheres

Staff members who award orders are not allowed to entertain private business relationships with RMF subcontractors. As an exception, the services of subcontractors can be drawn upon for private purposes if these services are available for the entire workforce at set conditions. Any further exceptions and details can be governed by work regulations in force in the division concerned.

Other Employment

No employee shall accept employment in addition to her/his employment with RMF unless s/he has the written authorization of the Management to do so. In order to obtain such authorization, the employee shall make a written request to the RMF Headquarters describing the nature and conditions of the proposed employment. Permission will be granted only if the Management is convinced that the employee will not be put in a situation where there are conflicts of interest, and that the effective performance of the employee’s duties for RMF will not in any way be impaired. This permission may be revoked if the Management has determined that the employee’s effective performance of her/his duties has been impaired by her/his additional employment, or that a conflict of interest has arisen.

Conflict of Interest, Extra-contractual Activities

RMF must give its permission for any extra-contractual activities. Paid activities (money or in kind) on behalf of clients or organizations with whom RMF entertains business relationships are only permissible if it appears thatRMF’s interests will not be impaired.

Non-Violation of Sarbanes-Oxley

No Board member, Management personnel, nor staff shall in any manner violate the Sarbanes-Oxley Act (15 U.S.C.7201-7266) and shall disclose to the RMF Board any activity which in anymanner may relate to Securities.

Other Employment

No employee shall accept employment, in addition to her/his employment with RMF unless s/he has the prior written authorization of the Board to do so. The employee shall make a written request to the Board describing in detail the nature and conditions of the proposed other employment. Permission will be granted by the Board only if the Board is convinced that the employee will not potentially be placed in circumstances which may create a conflict of interest, and the effective performance of the employee’s duties will not be negatively affected.

Duty of Employee to Report Actual or Potential Conflict of Interest

All employees are advised that they must declare whether there is or potentially may be a Conflict of Interest due to business, commercial, and/or financial holdings. It is the on-going duty of all employees to submit a written disclosure immediately upon learning of any such real or potential conflict.

Conflicts of Interest in General

In our work, conflicts may arise between our personal interests and RMF’s interests or those of our partners and/or independent contractors. Employees must immediately reveal any such Conflicts of Interest in writing to the Board. The Board will investigate and use objective criteria in deciding whether there is a Conflict of Interest and appropriate action.

Extra-Contractual Activities

RMF must give its written permission for any extra-contractual activities on behalf of clients or organizations with whom RMF is doing business; RMF will not with hold such permission if it is found that RMF’s interests and the interests of their partners and independent contractors are not impaired.

Personal, Financial Connections

Any employee, Board Member, staff member, and/or member of Management may have personal, family, financial, or business connections to RMF’s business partners or independent contractors, or competitors. The employee, Board Member, staff member and/or member of Management must immediately disclose, in writing any such relationship or connection to the Board. If any such relationship is found, the employee, Board member, staff member and/or member of Management is automatically and temporarily excluded from any decision-making related thereto, until after the RMF Board has made a decision as to how to handle the conflict.

Litigation of Any Kind

All RMF employees are required to immediately report to the Board, in writing, any litigation in which they are involved and subsequently upon the receipt of any summons, complaint, discovery, and/or investigation documentation of any nature.

Disciplinary Action

All employees of RMF are subject to disciplinary action if warranted. Disciplinary action can range from oral or written reprimand, to temporary suspension from duties without pay, or termination of service. Reasons for such disciplinary action may include, but are not limited to the following examples:

  1. Deliberate false statement; misrepresentation, concealment of material facts; fraud.
  2. Insubordination;
  3. Failure to comply with RMF’s rules, policies or procedures;
  4. Repeated unexcused tardiness, absences or abuse of sick leave;
  5. Unsatisfactory performance of duties;
  6. Breach of Confidentiality;
  7. Violation of standard of conduct or conflict of interest guidelines;
  8. Unauthorized use of RMF offices, vehicles, equipment, material, or property.

Ethical Standards

RMF expects its employees to observe the highest ethical standards of business ethics. No employee shall take any action on behalf of RMF or which tends to communicate to the public that the employee is acting with RMF’s authority, approval and/or consent that they know, or reasonably should know, violates any applicable law or regulation. The employee shall never accept gifts, gratuities, entertainment nor anything of value from any individual, company, NGO, contractor, or government employee with whom RMF does business or has any relationship whatsoever. Violation of this paragraph is grounds for immediate termination.