Code of Ethics

Our mission is fundamental to who we are and what we do, and the principles behind it form the basis of this Code. We follow all the legislative and regulatory provisions that govern how we operate.

We are honest in our communication and business relationships

We are honest and clear when speaking with patients and their relatives, members of staff, auditors and inspectors, government bodies and their representatives, and everyone else we deal with. We do not make misleading statements about our services or those of our competitors.

We are honest in documenting the care we provide, in charging for materials and services, and in the financial claims we make. Billing and collection procedures at the hospital are transparent: patients are informed both before and during their stay of the state of their account and of the cost of each examination they are to undergo.

We operate in line with competition law

• We conduct our activities within the framework of fair competition and in strict compliance with all applicable legislation.
• We do not engage in actual or apparent activities that could be interpreted as collusion aimed at undermining a fair and competitive market.
• We do not accept bribes of any kind, from suppliers, buyers or anyone else.
• We do not breach commercial confidentiality, deceive, or take part in similar unfair practices.
• We do not copy material protected by intellectual property law, and we do not make improper use of a competitor's confidential business information.
• We comply with lawful and reasonable requests for information from government services and auditors in a timely and orderly manner, and treat all inspectors and auditors with respect. Bribery and personal favours of any kind to public or government officials are prohibited.

At Napa Olympic Private Hospital, people make the difference, and every employee performs important work. We aim to recruit and retain the best staff, offer competitive pay and benefits, apply policies and procedures for fair treatment, communicate openly and honestly, listen to our people, support their development and maintain a positive and safe working environment.

We follow the principles of the United Nations Global Compact, based on the internationally recognised principles of human rights protection set out in the Universal Declaration of Human Rights.

• We support equal employment and treat one another with fairness and respect.
• We do not permit discrimination on grounds of sex, race, national origin, religion, colour, age, family status, sexual orientation or disability.
• We recognise diversity among our staff and partners as a source of strength in providing quality care.
• We do not permit the recruitment or employment of anyone below the legal working age, and we ensure our partner companies adopt the same policies.
• We do not permit sexual or any other form of harassment.
• We work to build an environment of understanding and respect, in which anyone can raise and discuss concerns about ethical conduct openly, particularly with their supervisor, without fear of punishment or any form of retaliation.
• We recognise the importance of family and other obligations and help one another resolve any conflict between those and work.
• We recognise the right to freedom of association and to collective bargaining.

Quality care

Everything we do advances our commitment to providing the highest quality of care. We follow the six characteristics of quality care defined by the Institute of Medicine (2001):

• Safe — avoiding harm to patients as a result of the care provided to them.
• Effective — providing services based on scientific knowledge, best practice and cost-benefit.
• Patient and family centred — care that respects and responds to the individual preferences, needs and values of the patient and family, ensuring patient values guide clinical decisions.
• Timely — reducing waits and sometimes harmful delays, for those receiving and those providing care.
• Efficient — avoiding wasteful use of resources, including equipment, materials, ideas and energy.
• Equitable — care that does not vary in quality because of personal characteristics such as sex, ethnicity, geographic location, socio-economic status, sexual orientation or perceived disability.

We treat all patients with dignity, respect and courtesy, and provide clear, accurate, honest and transparent information about the quality of our care so that patients can make informed decisions. We have provided and facilitate easy access for patients with mobility difficulties, and we maintain safety rules inside the hospital and in the surrounding grounds. We take every appropriate measure for the safety of high-risk patients, and our staff are suitably and sufficiently trained for such cases.

Every patient receives full and valid information on admission about their stay, the hospital's regulations and the discharge procedure. A formal procedure exists for submitting suggestions, observations and complaints; the Quality Directorate handles complaints and coordinates the response in each case. We consider it our duty to report errors or gaps in the care we provide to our superior or to Management, even where they appear minor.

Patients' rights and choices

We inform and encourage patients and their relatives to take part in decisions about their treatment so far as is practical and possible and as provided by law. Patients and families are made aware of their rights and obligations on admission. Particular care is taken for specific groups — minors, elderly or vulnerable patients, patients with disabilities, and foreign nationals who do not speak Greek — so that information is given in the most understandable and appropriate way in each case.

We provide our services only after informing patients of their actual state of health, the proposed medical procedure, the alternative therapeutic options, and the risks and expected outcomes. Prior consent is required for diagnostic and therapeutic procedures such as invasive and surgical procedures and the administration of anaesthesia; consent forms are signed and recorded in the patient's file.

We respect the wish of some patients not to be informed of their condition, which implies another recipient of the information; this does not set aside the principle of informed consent. For patients with terminal illness we provide palliative care and work with their families to relieve both psychological and physical symptoms. We provide a coordinated discharge plan wherever it forms part of the care plan. We respect patients' religious, philosophical, ethical and cultural views, and our own views on a patient's lifestyle, beliefs or social or financial position do not affect the care or treatment we provide.

Emergency care

We provide our services for emergency cases even where the patient is unable to pay or is not covered by insurance, until the patient is stabilised and referred to a doctor of the appropriate specialty or transferred to a suitable care facility.

Charitable care and discounts

We offer financial assistance to patients in the form of discounts or free charitable care, provided in a way that responds to the individual financial circumstances of the patient.

Second medical opinion

In seeking to provide the best possible diagnosis and treatment, we accept the patient's right to a second medical opinion.

Disagreement within a patient's family about treatment

Our services are provided according to the fundamental principles of bioethics: respect for autonomy, beneficence, non-maleficence and justice, particularly in addressing and resolving ethical dilemmas, always in compliance with the legal framework and in the patient's interest. Sole responsibility for a patient's treatment rests with the treating physician, who ensures timely and honest communication with the patient and their relatives. Medical and nursing staff work to clarify the patient's condition fully and to smooth over any disagreement between family members, maintaining the calm environment that a hospital requires. Bioethical questions and related disagreements may be referred to the Ethics Committee for an opinion.

Patients and their families entrust us with highly personal and sensitive information about their medical condition. If they do not feel confident that we safeguard the privacy and confidentiality of that information, they may hesitate to discuss concerns that could affect medical decisions and impede their care.

We comply with the General Data Protection Regulation and national legislation, and we apply an Information Security Policy that includes the following:

• We access, use and disclose only the minimum patient information required to do our work.
• We do not discuss patients' personal and health data with third parties who have no reason to know and no connection to that patient's care, including colleagues, partners, family and friends.
• We do not share user credentials or system passwords, and we log off when leaving a computer.
• We assess our surroundings when speaking with or about patients, speak quietly, and always ask permission before discussing a patient's care in front of companions or relatives.
• We check patient files to ensure one patient's data is not mixed with another's and that patient labels are correct and accurate.
• We store patient files so that access is limited to those who require it for their work.
• Documents containing personal or health data are never discarded in general waste; they are held until securely destroyed as the law requires.
• We report all privacy concerns or possible breaches of the Information Security Policy immediately to the hospital's Information Security Officer.

The hospital maintains a medical record, electronic or physical, containing sensitive personal data relating to patients' health. Test results are released only to the patient themselves, or to a person the patient has designated, under procedures that are lawful and accepted. The hospital has established the role of Data Protection Officer, who holds guarantees of independence, monitors compliance with the law and acts as the point of contact with the supervisory Data Protection Authority.

The principles we apply to all processing

• Lawfulness, fairness and transparency
• Purpose limitation
• Data minimisation
• Accuracy
• Storage limitation
• Integrity and confidentiality
• Accountability of the controller

The rights we safeguard

• Information and access — fuller and clearer information at the point of collection, and the right to access the data held.
• Rectification — the right to require correction of inaccurate data and completion of incomplete data.
• Restriction of processing — the right to obtain restriction of processing under specific conditions.
• Objection — the right to object to processing under specific conditions, particularly profiling or direct marketing.
• Data portability — the right to receive or have transferred, in machine-readable form, data from one controller to another under specific conditions and where technically feasible.

All patient data, personal and sensitive, is confidential and may not be disclosed to any third party except where the data subject consents, where a provision of law requires it, or where a court order directs it. Disclosure to third parties is otherwise prohibited, other than where required by law — for example to judicial and prosecuting authorities, tax authorities, state bodies acting within their statutory powers, court bailiffs, the social insurance bodies to which the insured person compulsorily belongs, and insurance companies with which the patient holds a policy and which the patient has expressly authorised to request health information.

Employees are prohibited from disclosing or passing on information that comes to their knowledge through their work, in particular the results of medical procedures and examinations, to any third party other than the patient, unless that party holds written authorisation from the patient with a signature certified by a public authority. Staff in the Medical Records Department may not release material from patient files to any third party, including relatives, unless specifically and expressly authorised. Employees may not make announcements or statements to any third party, and in particular to the media, concerning a patient's admission, the medical services provided or their state of health. Employees may not appropriate or use the hospital's patient list for any reason.

These obligations continue after employment ends: the employee must hand over all data and material held by reason of their work, and must continue to keep confidential all patient data that came to their knowledge. Employees also safeguard the personal and sensitive data of colleagues that comes to their knowledge through their work.

In this section, "we" refers to the individual employee rather than the hospital.

• We do not allow outside activities, financial or other personal interests to affect our ability to make fair decisions in the course of our work.
• We select medicines, materials and medical equipment on the basis of their performance in patient care and their cost, not on the basis of personal relationships or friendships.
• We avoid recommending or working with companies in which members of our family hold a financial interest, unless we have reported it to Management and obtained prior written approval.
• We do not allow personal relationships to bias recruitment decisions unfairly.
• If we believe we may have a conflict of interest, we report it to Management.

The hospital voluntarily follows and complies with the Tenth Principle of the United Nations Global Compact, based on strengthening transparency as set out in the United Nations Convention against Corruption. Except where stated, "we" below refers to the individual employee.

• We avoid even the suspicion of improper or unlawful influence in the provision of care to patients.
• We do not solicit, accept or offer money, gifts, entertainment or other items of value, or any other benefit, to influence the referral of patients to us.
• We do not solicit, accept or offer money, gifts, entertainment or other items of value to influence the procurement of goods or services, the leasing of premises or equipment, or the award of contracts.
• We do not offer patients goods or services free of charge or at a discount without the approval of Management.
• We do not ask or require money, gifts or any other personal benefit from patients or their relatives. Accepting a voluntary gratuity or token gift offered spontaneously as a sign of gratitude is permitted under the hospital's rules, provided it does not affect the quality of care provided and does not entail any preferential treatment of patients.
• We do not offer any financial incentive, gift, fee or bribe to induce, influence or reward the decisions of a public body, client, subcontractor or supplier, or of any person in a position to favour the hospital or its officers.
• Donations to political formations or persons associated with them are prohibited. Employees are also prohibited from representing, or appearing to act on behalf of, the hospital in any political activity they carry out in their private lives.

We use the hospital's assets and fixed property solely for the benefit of the company and never for personal gain. Assets include patient files, intellectual property rights, research data, business strategies and plans for the hospital's corporate activity. We have an obligation to protect both the tangible and the intangible assets of the hospital.

Coding and charges

The hospital takes care to ensure that bills issued to the state, to third parties and to patients are accurate and in accordance with applicable laws and regulations. Coding is the method of identifying and classifying health information — diagnoses and procedures, materials and medicines — as provided to the patient and documented in their file. Our commitment to timely, complete and accurate coding and billing includes the following principles:

• We charge for services actually provided, documented in the patient's file and carried out in accordance with the treating physician's instructions.
• We assign billing codes that we believe accurately represent the services we provide and that are supported by documentation in the patient's file.
• We apply controls to prevent overcharging, duplicate charges for the same service and other billing errors.
• We respond to enquiries concerning coding and charges and promptly resolve inaccuracies identified and confirmed in issued accounts.
• We make every effort to ensure that employees and subcontractors who bill or code services have the necessary qualifications, quality assurance procedures, and appropriate mechanisms to ensure charges are accurate and complete.
• We do not knowingly claim payments that are false, fictitious or fraudulent.
• We inform the patient immediately on admission of the deposit payable according to their accommodation class, and of the expected cost.
• In seeking to control patient charges, we ensure patients undergo diagnostic and other examinations only where the treating physician judges them necessary.

Integrity of financial and non-financial reporting

We maintain a high standard of accuracy and completeness in documenting all our financial records. These records form the basis of the hospital's business management and are essential to meeting our obligations towards patients, staff, suppliers and all interested parties, as well as to our compliance with tax requirements and financial reporting. The accounting records and supporting documents are designed to describe and reflect the true nature of the hospital's transactions.

Our financial information represents transactions actually carried out and is provided in accordance with generally accepted accounting principles and applicable law. We cooperate fully with internal and external audit and regulatory bodies, and we are obliged to give auditors accurate and truthful information. The company's financial statements are prepared in accordance with International Financial Reporting Standards (IFRS) and audited by certified auditors as the law requires.

Our relationship with shareholders

The hospital's established control mechanisms and procedures safeguard transparency and integrity towards shareholders and investors. Through ethical management and transparency, the company ensures systematic, prompt, clear and equal information for the investment community on financial data, business developments, strategy and objectives. Specific individuals are authorised to communicate with the financial community; an employee who receives questions without express authority to answer should pass them to the Finance Directorate.

The Board of Directors is the guardian of the principles of corporate governance. Its structure and responsibilities are recorded in the company's articles of association and comply with current legislation, and its members have been elected according to the independence criteria the law provides.

The Board is made up of members of integrity, breadth of knowledge, appropriate qualifications and experience, for the purpose of setting corporate strategy and overseeing Management, with the aim of maximising the value of the company and safeguarding the rights of shareholders and stakeholders generally.

• We are committed to protecting the environment and preventing pollution, to defending occupational health and safety, and to preventing workplace accidents and occupational illness.
• We are moving towards "green" operating practices, applying an environmental policy covering the construction of spaces, energy saving, control of water and paper consumption, reduction of waste and its proper management.
• We monitor and apply national and European environmental legislation and all legal and regulatory requirements. Our compliance with the law, and our initiatives that go beyond merely meeting legal requirements, are strategic corporate objectives.

We are responsible for complying with the ethical standards, regulations, policies and procedures issued by the hospital. Compliance with applicable legislation is a duty and a basic obligation of every employee.

Our commitment to these principles and values must be secured through the daily conduct of every one of us. Each of us needs to understand clearly what ethical business conduct is required.

We adapt our strategic planning with our healthy development in mind, taking business decisions and making use of every opportunity that creates added value, with long-term focus. Our priority remains that all services provided by our hospital match the highest quality worldwide.

As part of continuous self-assessment and self-improvement, the views of our employees matter, and we accept suggestions for improvement and comments from our staff.

We reduce any deviation from our operating standards and from international best practice through appropriate quality improvement actions, and we monitor their effectiveness through indicators and measurements. Wherever deviations or undesirable trends in performance are identified, we take the appropriate corrective action.