EBMcalc Medical Calculator

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EBMcalc Business Ethics Policy

1. Purpose and Scope

This policy establishes the ethical framework for our operations. We maintain a zero-tolerance stance toward bribery and corruption. This applies to all employees, contractors, and third-party representatives acting on our behalf, regardless of local customs or competitive pressures.

2. Business Ethics & Integrity

We commit to conducting business with honesty and transparency.
Compliance with Laws: We adhere to the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and all local anti-corruption laws in the jurisdictions where we operate.
Conflicts of Interest: Employees must avoid situations where personal interests interfere—or appear to interfere—with the interests of the company.

3. Gifts, Hospitality, and Entertainment

While building relationships is a standard part of business, the exchange of gifts or entertainment must never be used to influence a decision or gain an unfair advantage. Category Guidelines for Private Sector Customers Guidelines for Government Officials Gifts Must be modest, infrequent, and branded (e.g., pens, calendars). Strictly Prohibited in most cases. Requires prior Legal approval. Meals Occasional and reasonable in value. Must have a clear business agenda. Must be modest and permitted under local law. Entertainment Standard sports or cultural events are generally okay if the host is present. Highly sensitive. Usually prohibited to avoid the appearance of bribery.

4. Payment of Commissions & Third Parties

Payments to third parties (agents, consultants, or distributors) are often the highest risk area for corruption.
Due Diligence: All third parties must undergo a compliance background check before engagement.
Written Contracts: All commission structures must be documented in writing, reflecting fair market value for services rendered.
No "Success Fees" for Government: We do not pay commissions to third parties for the purpose of influencing a Government Official to secure a contract.

5. Interaction with Government Officials

Interacting with "Government Officials" (which includes employees of state-owned enterprises) requires extreme caution.
Facilitation Payments: Small "grease payments" made to expedite routine government actions (like processing a visa) are prohibited, even if they are common practice in a specific country.
Political Contributions: Company funds may not be used for political contributions without Board-level approval.

6. Reporting and Non-Retaliation

If you suspect a violation of this policy, you have a duty to report it immediately through your manager or the anonymous Compliance Hotline. Our Guarantee: The company strictly prohibits retaliation against any individual who reports a concern in good faith.

If there are any questions regarding this policy, you may contact us using the information below.

http://EBMcalc.com
P.O. Box 81782
Pittsburgh, PA
15217 U.S.A.

Legal Notices and Disclaimer

All information contained in and produced by the EBMcalc system is provided for educational purposes only. This information should not be used for the diagnosis or treatment of any health problem or disease. THIS INFORMATION IS NOT INTENDED TO REPLACE CLINICAL JUDGMENT OR GUIDE INDIVIDUAL PATIENT CARE IN ANY MANNER. EBMcalc is NOT a medical device. EBMcalc NEVER stores cookies or other persistent data in user's browsers. Click here for full notice and disclaimer.