Cambridge Cardiac Care Centre

Cambridge Cardiac Care Inc. Anti-Bribery and Anti-Corruption Policy

1.1. Cambridge Cardiac Care Centre (CCCC), and its subsidiaries, is committed to conducting the business of medical practice ethically and with the utmost integrity, including compliance with all relevant laws and regulations against bribery and corruption in Canada.

1.2. CCCC has a zero tolerance policy with respect to bribery and corruption in all facets of its dealings. CCCC prohibits all forms of bribery or corrupt conduct, whether involving Government Officials or commercial (private) sector persons or companies, and whether direct or through a third party acting on behalf of CCCC.

1.3. CCCC Personnel shall act at all times with the utmost integrity and highest ethical standards in fulfilling all of their duties, and not take any action that could compromise their judgment and/or best practices. Accordingly, CCCC personnel and employees shall never request or accept any payment or anything of value that could influence, or could be perceived as influencing, the execution of their duties. This includes accepting inappropriate gifts or hospitality, kickbacks, or investment opportunities from private individuals or entities conducting (or seeking to conduct) business with Cambridge Cardiac Care Centre and its affiliates.

2. Definitions

2.1. For purposes of this Policy, these terms have the following meanings:

2.1.1. 2.1.1. “Bribery” is the offering, authorizing, promising, providing, requesting, accepting, or receiving of anything of value, either directly or indirectly, to or from an individual or company, in order to secure an improper advantage.

2.1.2. 2.1.2. Not all bribes are payments of cash. A bribe can be made with “anything of value,” which includes, but is not limited to, money, business opportunities, preferential treatment or terms, confidential information, employment opportunities, favors, meals, travel, entertainment (such as tickets to a sporting event), gifts, political contributions, or charitable donations. Furthermore, to constitute an offense under one or more of the relevant laws and regulations against bribery and corruption, there need not be an actual exchange of something of value -- an offer or solicitation may be sufficient.

2.1.3. “Government Official” means:

i. Any officer or employee, appointed or elected, of a local, regional, provincial; or federal government, or any department, agency, ministry, or instrumentality of a government;

ii. Any physician or other health care professional (“HCP”) employed by a public hospital or clinic;

iii. Any individual who, although temporarily or without payment, holds a public position, employment, or function;

iv. Any officer or employee of a public international organization, such as the United Nations, the World Health Organization, or the World Bank;

v. An individual acting in an official capacity for or on behalf of a government department, agency, ministry, instrumentality, or public international organization;

vi. A political party official, officer, or employee, or any candidate for political office;

vii. Any officer or employee of an entity owned or controlled by a government, as well as entities that perform a governmental function (e.g., air or sea transport, utility, energy, water, or power); or

viii. A member of a royal family, including one who may lack formal authority, but could otherwise be influential in advancing CCCC’s business interests. Family members or close associates of any of the individuals listed above may also qualify as Government Officials if interactions with them are intended or have the effect of conferring anything of value on a Government Official.

2.1.4. “CCCC Personnel” includes officers, directors, and full-time, part-time, temporary and contract employees of Cambridge Cardiac Care Centre and its affiliates, as well as consultants and independent contractors providing services on behalf of CCCC.

3. Scope

3.1. All CCCC Personnel are responsible for carefully reviewing, understanding, and abiding by this Policy at all times.

3.2. CCCC also expects all business partners that work with, for, or on behalf of it to abide by the same standards of ethical conduct and compliance set forth in this Policy.

4. Requirements

4.1. CCCC Personnel shall never directly or indirectly offer or pay, or authorize an offer or payment, of money or anything of value, to a Government Official, HCP, or any other person or entity (including those in the commercial/private sector), which is:

4.1.1. Intended to corruptly influence the judgment of the recipient in exercising his or her job responsibilities;

4.1.2. Intended to corruptly secure preferential treatment or an improper advantage for CCCC or its affiliate entities, or;

4.1.3. Intended as gratitude for the recipient having made a decision or acted in a way that improperly benefited CCCC or its affiliate entities.

4.2. CCCC Personnel shall not directly or indirectly request or accept any money or anything of value that is:

4.2.1. Intended to corruptly influence the judgment or conduct of CCCC Personnel in his or her job responsibilities, or;

4.2.2. Intended as gratitude for having made a decision or acted in a way that improperly benefited the person or entity giving anything of value to CCCC Personnel.

4.3. All CCCC Personnel are expected to comply with relevant local laws related to anti-bribery and anti-corruption, as well as the laws of any other applicable jurisdictions in which we do business.

4.4. CCCC Personnel shall never engage a third party to do anything that would be prohibited by this Policy if undertaken by CCCC Personnel.

5. Interactions with Government Officials

5.1. Bribery and corruption risks exist in our contacts and business relationships with individuals and entities in the commercial (private) sector as well as our interactions with Government Officials.

5.2. As defined above, the term “Government Official” is broadly interpreted. This means that HCPs who are employed by, teach at, or have privileges with, a government hospital or public university are Government Officials—even if they only work there part-time.

6. Facilitation Payments and Duress

6.1. A facilitation payment is a nominal, unofficial payment to a Government Official for the purpose of securing or expediting the performance of a routine, non-discretionary governmental action. Such payments are illegal in most countries. CCCC prohibits personnel from offering, authorizing, or making any such facilitation payment (directly or indirectly). All requests or demands for facilitation payments or bribes must be reported to senior management at Cambridge Cardiac Care.

7. Third Parties and Other Business Partners

7.1 CCCC expects those it does business with to act according to the same high ethical standards that it holds for itself. A business partner must never be engaged to do something that would be prohibited by this Policy if undertaken by CCCC Personnel.

7.2. CCCC Personnel should be aware that individuals soliciting bribes will often seek to involve intermediary companies to disguise the true recipient and purpose of the payment.

7.3. We require that reasonable due diligence be conducted before retaining business partners and monitoring their activities afterward. The amount of due diligence and monitoring must be proportional to the risk of corrupt activities occurring in the geographic region, industry, or specific act in question.

8. Books and Records and Internal Controls

8.1. It is CCCC’s policy to keep books and records that accurately, transparently, and fairly reflect transactions in reasonable detail, and to maintain a system of internal controls designed to prevent and detect potential violations of CCCC’s policies or of applicable laws. No false or artificial entries may be made in the books and records for any reason, and all payments and transactions, regardless of value, must be recorded accurately.

8.2. All expenses incurred by CCCC Personnel shall be supported by a detailed description of activities and the actual, valid receipts or invoices reflecting amounts incurred. The knowing submission or acceptance of false receipts and/or invoices is strictly prohibited.10. Compliance with this Policy

9.1. If you have any questions about this Policy or what the Policy or the relevant laws and regulations require of you, please contact CCCC senior management. Report any concerns through an anonymous and confidential email to

9.2. Any violation of this Policy or related procedures by CCCC Personnel may have significant consequences for them and CCCC, including potential prosecution, fines, and other penalties, as well as imprisonment and/or disciplinary action -- up to and including employment termination, consistent with local laws.

9.3. Violations of the principles set out in this Policy by CCCC business partners may result in termination of the business relationship, among other legal actions and potential consequences.

10. Reporting Violations

11.1. CCCC Personnel who know of, or reasonably believe there has been, or imminently will be, a violation of this Policy and/or related procedures, or any applicable anti-corruption laws and/or regulations, must report that information immediately to CCCC senior management. Report any concerns through an anonymous and confidential email to

11. Auditing and Monitoring

11.1. This Policy, together with supporting documentation and records required by it, is subject to periodic auditing and monitoring.

13. How to Report

12.1. CCCC Personnel may report any concerns through an anonymous and confidential email to CCCC Personnel may also make confidential reports to his/her supervisor or senior management..

13. Summary and Exceptions

13.1. This Policy is intended as a general reference guide, and it does not describe all applicable law or Company policies or procedures, or give full details on any individual law, policy, or procedure, or address any and all potential situations that CCCC Personnel may find themselves in.

13.2. CCCC reserves the right to modify, revise, or alter this Policy and any related procedure at its sole discretion. This Policy is not a contract or legal document and is intended for informational use only.

13.3. Any exceptions to the requirements of this Policy must be approved by CCCC senior management.