Code of Ethics & Business Conduct

Last updated on 5 November 2023

Code of Ethics & Business Conduct


This Code of Ethics and Business Conduct (“Code”) applies to everyone, including officers,directors, employees, contract workers, and agents of Planetree International Inc. (“Planetree”) and its direct and indirect majority owned or controlled affiliates worldwide. This Code of Ethics & Business Conduct is a supplement to all applicable federal, state and local law and regulation to the extent this policy is contrary to any federal, state and/or local law and/or regulation, the federal, state and/or local law and/or regulation will preempt the terms herein.

Respecting Human and Labor Rights

We respect human rights and fair labor practices. We comply with applicable laws and are guided by the principles described in the United Nations Universal Declaration of Human Rights and the International Labor Organization’s 1998 Declaration on Fundamental Principles and Rights at Work.

We condemn the use of exploitative and illegal child labor and do not accept any form of forced labor including modern slavery and human trafficking.

We respect the principles of freedom of association and the right to effective collective bargaining, including the rights of our employees to freely choose whether to be represented by a particular trade union, in accordance with applicable law.

We endeavor to perform our activities in a safe way and give top priority to the health and safety of our employees, of our business partners and their workforce who assist in our operations, and of the people who live and work near our sites.We foster a culture in which everyone feels responsible for reducing risks and promoting safe practices.

Inclusion and Diversity

We value inclusion and diversity. We promote inclusion as a sense of belonging and being valued. We can attain our potential and achieve higher levels of performance and innovation only if all employees at Planetree embrace diversity and contribute their perspectives, individual talents, and experiences.

Discrimination-and Harassment-Free Work Environment

Planetree supports equal opportunities for its employees and does not tolerate discrimination or harassment, including sexual harassment. We do not tolerate any form of discrimination based on race/ethnic origin, color, citizenship,sex, gender identity, gender expression, sexual orientation, physical/mental disability, religion, age, marital or familial status, or any other category protected by law.

Planetree is committed to maintaining a high standard of conduct in the workplace and providing a work environment free from harassing, offensive, or inappropriate conduct. Such conduct violates the fundamental dignity and mutual

respect all people deserve, complicating the efficient operation of our mission and posing risk to successful mission accomplishment at Planetree.


We are dedicated to hiring qualified team members. Some duties at Planetree require you to have a license, certification, or other professional credentials or health-related certificates. You are responsible for maintaining all required credentials to perform your work. You must promptly report to your supervisor if any needed credential is expired or revoked. In some countries, government agencies may exclude certain individuals from participating in health care activities. If you receive notice that you are excluded from participating in any government program, you must promptly notify your supervisor.


As a global Company, we strive to comply with the anti-corruption laws of all countries in which we operate, including the U.S. Foreign Corrupt Practices Act (“FCPA”),the UK Bribery Act, and the German Criminal Code.

Planetree does not tolerate bribery, corruption, kickbacks, or the provision of any improper benefits anywhere in the world, whether it involves health care professionals,government officials, or any other private party.

You should never offer, authorize, or provide a payment or anything else of value with the intention of improperly influencing any person. You should also never request,accept, or agree to accept anything of value from any person attempting to influence your business decisions.

Anti-Money Laundering

Planetree is committed to complying with laws that prohibit money laundering. Money laundering is broadly defined as engaging in a transaction involving criminally derived property, structuring a transaction to avoid a reporting requirement designed to detect criminal conduct, or engaging in a transaction in furtherance of criminal conduct.

We take necessary steps, including risk-based due diligence, to conduct business with reputable business partners involved in legitimate business activities using funds derived from legitimate sources.

Trade Governance

Planetree is dedicated to acting in compliance with trade laws that apply to our business.Trade laws are any laws that govern the trade, import, export, transfer, and movement of goods, services, technologies, and funds. Planetree monitors tradelaws and implements policies to make sure we follow them. Violations of tradelaws can have profound consequences for Planetree and the individuals involved.

Competing Fairly

We pursue fair competition and must conduct our business in compliance with all applicable antitrust, competition, and fair dealing laws. The consequences of violations can be severe for you and us.

Supplier Selection

When selecting suppliers and contractors, we use transparent processes and consider sustainability criteria. Our procurement strategy includes striving for, where reasonably practicable, at least two sources both for supply-critical andprice-critical products or services. We ask our suppliers to apply high ethical standards in their own operations and supply chains. Team members who order products and services must follow these standards, the law, and our procurement policies.

Conflicts of Interest

We act in the best interests of Planetree and seek to safeguard our reputation. From time to time, you may have relationships or arrangements outside Planetree that may conflict with the interests or mission of Planetree.

For instance, a“conflict of interest” may arise if one of the following applies:

·        You or a family member have a financialrelationship with an organization with which Planetree has, or proposes tohave, business dealings or with which Planetree competes. This financialrelationship can take many forms, including employment, ownership,participation as a board member, or other relationships. For instance, if youare a manager and also employed by a competitor or a supplier to Planetree, aconflict of interest may exist

·        You or a family member has any relationship that may influence your decision-making in your role as a Planetree employee. For instance, if your position enables you to recommend or refer business to a company in which you or a family member has an interest or relationship, you may have a conflict of interest.

We expect you to disclose any conflicts of interest to your supervisor as soon as you become aware of such conflict. The supervisor is responsible for taking appropriate measures to protect you and Planetree from harmful or inappropriate decision-making.

Accurate Books and Records

Accurate business records are essential to our operations. They help us to fulfill our obligation to provide full, accurate, and timely financial reports and disclosures required by law.

Accurate records are necessary to enable business decisions and to successfully direct our business. All our books, records, and accounts must fully and accurately reflect our business transactions and be supported with sufficient and precise documentation. These records include financial statements, time sheets,vouchers, bills, invoices, expense reports, payroll and benefits records,performance evaluations, and all other relevant Company data.

You must maintain all paper and electronic records in accordance with our policies and the law. You also must adhere to internal control requirements to ensure financial records and accounts are accurate.

Billing Practices

Planetree iscommitted to accurate, truthful, and complete billing for our products and services. In support of accurate billing, all records must provide reliable documentation of the services rendered or received or of the products purchased or sold. Accurate and timely documentation also depends on the diligence and attention of all personnel responsible for maintaining the records. Each person is responsible for providing complete, legible, and accurate information in a timely manner.

Privacy and Personal Data

Planetree takes privacy and security seriously and respects the privacy of all stakeholders,whether they are patients, employees, customers, suppliers, or others. We will collect personal data only where we have a legal basis or legitimate business need to do so. We will be transparent and comply with laws and policies. Using personal data for any unlawful purpose or for pursuing personal benefit or interest is prohibited. Access to personal data, including patient and employee data, shall always be limited to a need-to-know basis.

Protection of Confidential Information and Trade Secrets

Company confidential information and trade secrets must always be kept confidential,regardless of whether the information is marked “confidential” or “restricted.”Your confidentiality obligations remain in effect even after your employment with Planetree has ended.

Intellectual Property

Intellectual property (patents, trademarks, copyrights, trade secrets, technical and scientific knowledge, or know-how) are among the most important assets of the Company. Protecting our intellectual property is critical to fostering innovation that enables Planetree to deliver superior products and services. We respect the intellectual property of others, never misappropriating or duplicating without authorization, and ensure that Planetree is a trustedpartner and avoids potential fines or penalties.

No Self-Dealing

As part of our commitment to acting in the best interests of the Company, you should never take personal advantage of business information gained through the performance of your duties. Any business opportunity you encounter in conducting business affairs on behalf of Planetree belongs to the Company and not you.

Information Requests from Governmental Authorities

Planetree does business in a transparent and compliant way. Accordingly, we respond to all government audits, reviews, and investigations in an appropriate manner. If you receive government requests that do not fall within your routine responsibilities, you should immediately contact your supervisor or the legal department. The legal department will coordinate all responses to such government requests. You are also asked to contact the legal department immediately upon receipt of any non-routine or potentially adverse request from any government agency or representative, such as subpoenas, warrants, and interview requests.

If employees are approached by any law enforcement agency outside Planetree grounds in connection with Planetree or their employment with or engagement by Planetree,employees are asked to immediately inform in-house counsel, unless the agency has prohibited them by law from communicating this fact.

Communication with the Media

Open and honest communication is a prerequisite for maintaining the trust of our patients,customers, and other stakeholders. Planetree can ensure that this communication is consistent only if statements and information provided to the media are pre-approved by the marketing department.

If you receive a request by the media for any information related to Planetree, you must refer the request to your manager. Each manager must forward such requests to the Marketing Department.

Advertising and Promotion

Planetree business activities and promotion of its products and services are sometimes regulated. We have developed specific policies to ensure business practices,marketing, and promotional activities comply with this Code and the law. All promotional material regarding Planetree products must be reviewed and approved in accordance with our policies.

Use of Social Media

Social media forms an important part of today’s business and the personal lives of our employees. Social media includes social networks, blogs, wikis, messaging apps,and video streaming websites. When using social media, every user is responsible for keeping internal and confidential information secure.

Political Activities

The legislative and regulatory processes that impact our business are complex and diverse. Itis appropriate for Planetree to periodically engage in policy discussions with regulators and to engage and collaborate with third parties to assist in lobbying and similar efforts. All such activities should be conducted under the guidance of our internal governmental affairs experts and in compliance with applicable law.

We also take society’s interest in transparency and openness into account. We recognize that individual employees engage in their own personal political activities. Such individual activities should be conducted separately and independently.Personal political activities by employees must not be or appear to be related to employment or engagement with Planetree. Employees must not use Companytime, property, or equipment for their personal activities.

Environmental Protection

We are dedicated to developing, producing, and applying our products and services in a sustainable way. This means we pay attention to how our business impacts the environment. We implement standards to minimize environmental risks, comply with environmental laws, and report accordingly.

We strive to use resources, such as energy, water, and raw materials efficiently, e.g.through recycling. We work continuously to reduce adverse effects of our activities on the environment and to increase awareness of environmental issues. It is your responsibility to comply with applicable laws, adhere to this Code and our policies for environmental protection and take all necessary precautions to avoid environmental incidents.

Donations and Sponsorships

We aspire to be a good corporate citizen and use resources to advance health care and other worthy charitable causes. We may make donations, particularly those intended to advance medical and person-centered care. We may also make donations to charities or civic organizations that provide services in the communities where we conduct business.

We do not make donations or contributions to obtain or retain business, or to secure an improper advantage. Any donation or sponsorship must comply with all applicable laws and our policies and requires prior approval by our internal experts. We are committed to tracking and being transparent about donation and sponsorship activities.

We may provide funding for educational events organized by reputable health care organizations and event organizers where the purpose of the event is to promote medical education or the understanding of scientific, clinical, or health care issues that contribute to the improvement of medical care.

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