Georgia Healthcare Group PLC Annual Report 2018 Strategic Report Resources and responsibilities continued • In 2018, our pharmacy and distribution business sponsored approach to preventing bribery and corruption in line with all the charity event “Festival of Life” organised by Monk Andrew’s applicable anti-bribery and anti-corruption laws. This Policy aims to: Foundation. The foundation takes care of children with oncology • outline principles for conducting business with integrity and in problems, gives them financial and psychological support and helps accordance with the highest ethical standards; them in the rehabilitation process. • provide guidance on the types of behaviour that may give rise • The healthcare services business also partners with Dimitri to violations of anti-bribery and anti-corruption laws; Tsintsadze Foundation, a charitable fund that helps children • ensure that the financial and other resources of the Group are used suffering from leukaemia and cancer, and the Monk Andria solely for their proper purpose; and Foundation and offers 20% discount on all our healthcare • promote a culture of honesty and openness among the Group’s staff. services for all of the fund’s beneficiaries. • With the support of the Caucasus Nature Fund (“CNF”), we This Policy applies to the Group and all of its Directors, Officers are involved in the Project of Maintenance of Caucasus Natural and employees at all times, and applies wherever the Group does and Cultural Heritage. The fund is meant for effective long-term business. The Group takes steps to ensure that all employees are management of the protected territories of Armenia, Azerbaijan aware of, and adhere to, the policy. and Georgia. In 2018, CNF announced a fundraising campaign The Anti-Bribery and Anti-Corruption policy can be found on the in connection with its tenth anniversary to support the region’s Group’s website: http://ghg.com.ge/uploads/files/antibribery-and- magnificent nature. GHG donated GEL 60,700 to the project. anticorruption-policy-20.pdf. Group Policies In 2018, the Group set up a new Internal Security department that Human rights closely watches and monitors day-to-day business and promotes We recognise the fundamental importance of human rights and are a transparent environment within the Group. The new department committed to implementing socially responsible business practices. has initiated a screening process that every newcomer and employee, The Group provides a safe working environment in which employees in case of promotion, should undergo. are treated fairly and with respect, and differences are valued. The Group is also committed to dealing fairly with our customers, competitors Several changes were introduced to the Group’s goods and services and suppliers. Our Corporate Handbook – Code of Conduct and Ethics procurement procedures as well. Every procurement, where the establishes our main priorities and puts internal controls in place that contractual amount is above GEL 50,000, must be carried out through provide equal opportunities and prevent discrimination or harassment open tendering. Tender participants are screened by the Internal Security on any grounds. The policy can be found on the Group’s website: department based on different criteria, such as experience, transparency, http://ghg.com.ge/policies. Our HR Policy applies to all employment works executed and environmental compliance. The screened bidders processes, including training and development. are allowed to participate in the tender, final the decision of which is subject to the Special Procurement Committee’s approval. Diversity We manage diversity and discrimination very carefully in the Group. Our To achieve the best quality of service and the highest possible ethical Diversity Policy clearly states that GHG is fully committed to elimination standards, the Internal Security department has started promoting of discrimination and values the differences that a diverse workforce freedom of speech. The purpose of this initiative is to convince brings to the organisation. According to our Employee Handbook, employees and others who have serious concerns about any aspect “The Company prohibits any form of discrimination against employees, of the organisation and its work to come forward and voice those patients, clients, partners, guests, job seekers or any third parties.” concerns. Thus, whistleblowing is viewed as a positive act that can make a valuable contribution to the Group’s efficiency and long-term We define harassment and complaints management in our Employee success. To encourage whistleblowing practice, starting from 2019, Handbook as follows, “Any employee who believes that there is an a hotline will be set up where any affected employee can raise their offensive or discriminatory conduct towards them or the working concern. The cases will be further analysed by the Internal Security environment is hostile, may file a complaint followed by the department and relevant measures will be taken. procedures according to the Workplace Dispute Resolution.” Whistleblowing policy can be found on the Group’s website: We carefully monitor our recruitment process to be fair to both internal http://ghg.com.ge/policies. and external applicants. All GHG employees can participate in the internal recruitment process, as vacancies are equally distributed across the Group. How we implement our policies across the Group In August 2015, GHG’s Board of Directors adopted and approved the In our healthcare business, 78% of applicants are female. On average, policies establishing minimum requirements and general standards for we have five shortlisted applicants per vacancy. We are proud to be environmental, social and employee matters, respect for human rights, the country’s biggest employer yet to have no complaints or litigations anti-corruption and anti-bribery issues, reviewed annually to ensure the from our applicants due to the recruitment process. Company is operating at maximum effectiveness. Through respective policies (found at: http://ghg.com.ge/policies), the Group recognises Within the scope of our CSR campaign, we provide employment that its activities may affect the environment and the community in opportunities to the people with disabilities. We are currently which it operates directly or indirectly and is committed to running its employing three persons with disabilities. We plan to advance this business in a responsible and sustainable manner in order to reduce project and give opportunity to more people for better inclusion. theenvironmental and social impact of its operations. Anti-bribery, anti-corruption and whistleblowing All policies were developed and issued based on the Group’s internal The Group and its subsidiaries are committed to ethical and honest standards. Approved documents were published on the Company’s business practices. We recognise the damaging impact that bribery intranet and internal policies and procedures platform. Some of them and corruption have both on the economy and on a business’ were also posted on the GHG webpage. After establishment of the reputation and credibility. The Group’s policy is never to offer, pay, Group’s general standards, each business line was responsible for request, solicit or receive bribes, or to facilitate, assist in or abet any developing a comprehensive procedure with all technical details and offer or payment of bribes and to refuse any request to pay them. activities to be performed for implementation of the respective projects. GHG’s Anti-Bribery and Anti-Corruption Policy sets out the Group’s 46