1. INTRODUCTION
1.1 Equashield Mission
To enhance human well-being through the utilization of innovative design, production and distribution of medical devices and instruments.
To provide advanced, automated, and innovative solutions to protect healthcare workers and facilities from the risks associated with hazardous drug exposure and contamination.
To strive for the greatest possible reliability, quality and efficacy of our products; to be the unsurpassed standard of comparison and to be recognized as a company of innovation, dedication, integrity, and service.
To recognize the intrinsic value of our employees by providing a professional environment that allows personal satisfaction in work, stability, promotion opportunities, and opportunities to share in the company’s accomplishments.
1.2 The Code of Conduct (“Code”)
Naturally, the field of medical devices has an impact on the health and lives of people; and therefore, it necessitates a great deal of financial and ethical responsibility. Equashield has always ascribed importance to the Company’s professional rules of ethics and requires its employees to conduct themselves accordingly, in a manner that is proper and fitting.
Ethics are expressed in various aspects of our day-to-day conduct of the Company, in decision making processes and management of employees and while working with customers, business partners and suppliers.
As part of fulfilling this vision, Equashield has formulated a written code of ethics which summarizes the practices that have guided the Company’s behavior since its establishment in 2009. The goal of the written code is to create clear language that defines the rules of conduct that will guide the employees in their work.
1.3 Our Stakeholders
1.3.1 Our Customers – Healthcare Professionals
Healthcare workers (whose lives can be saved with Company’s products) are at the heart of our Mission. “Healthcare Professionals” means those individuals or entities that are in a position to purchase, lease, recommend, use, arrange for the purchase or lease of or prescribe Equashield’s products or services. Examples include, but are not limited to, physicians, nurses, pharmacists, medical directors, hospitals, medical institutions and organizations, group purchasing organizations, managed care organizations, wholesalers and any individual employed by such entities. Healthcare Professionals are the cornerstone of our business.
1.3.2 Company and Shareholders
We seek to return a fair profit to our shareholders. We have a responsibility to ensure that our Company’s books and records are accurate, that the information we learn while performing our work is used properly, and that we treat these Company assets with great care.
1.3.3 Government Regulators
The medical device industry is dynamic and highly regulated by governments worldwide. Government Regulators work to protect the health and safety of their citizens and the integrity of their markets by enforcing appropriate laws and regulations. We fulfil our Mission and maintain our position as the trusted market leader when we follow the spirit and letter of all applicable laws and regulations, and supporting Company policies everywhere we work.
1.3.4 Communities and the Public
Our Mission commits us to maintaining good citizenship in all of the communities in which we live and operate, and to society in general. We strive to act responsibly in all aspects of our local, national, and global communities, including in the business, political, environmental, and philanthropic activities in which we participate.
1.4 Respecting Our Code
We all benefit from the Company maintaining a reputation for conducting business ethically and with integrity. The purpose of this Code is to inform Equashield employees, executive officers, members of the Board of Directors, independent contractors, consultants, sales agents, distributors and distributor employees, and all others representing or performing services on behalf of Equashield (“Company Representatives”), of Equashield’s high standards of business ethics, and to help Company Representatives engage in appropriate ethical and legal decision-making when conducting Equashield’s business in their day to day activities. It is a requirement for every employee to read, understand and comply with this Code of Conduct.
This Code applies to all Company Representatives as defined above who are engaged in activities in Israel, and should be provided to Company Representatives at the beginning of their relationship with Equashield.
This Code is intended to provide general guidance with respect to common legal and ethical issues that arise in the workplace. It cannot address every situation that may arise, and should be considered to contain minimum standards of ethical behavior. Company Representatives are expected to comply with both the letter and the spirit of applicable laws, regulations, policies and this Code, and are encouraged to seek guidance from supervisors or company executives should questions arise. In cases where local law and the requirements and expectations in this Code differ, we strive to follow the higher standards while complying with local laws. In case of a direct conflict between local law and the requirements and expectations in this Code, we will adhere to local law while seeking ways to respect the Code to the greatest extent possible.
2. GOVERNANCE AND BUSINESS ETHICS
2.1 Anti-bribery and corruption
Equashield has zero tolerance for corruption, including bribery, kickbacks, facilitation payments and fraud. Equashield refuses to accept or retain business through bribery and exercise fairness and transparency in all dealings with business partners.
No one representing the Company may directly or indirectly offer, promise, grant, or authorize the giving of money or anything of value to someone in order to unduly influence the recipient in the performance of professional duties or in order to obtain or retain an improper business advantage. We make sure gifts and hospitality always support a clear business objective and are openly disclosed and accurately recorded, of reasonable value, and appropriate to the nature of the business relationship.
We neither ask for, nor accept, improper benefits from others for performance of our duties to the Company.
2.2 Fair competition
Equashield supports the principles of free enterprise and fair competition and believe that free and fair competition leads to the best outcomes for consumers, society and our business. Competing vigorously, yet lawfully, with competitors and establishing advantageous, but fair, business relationships with customers and suppliers is a part of the foundation for long-term success. Unlawful and unethical conduct, which may lead to short-term gains, may damage a company’s reputation and long-term business prospects. Accordingly, it is Equashield’s policy that Company Representatives must endeavor to deal ethically and lawfully with Equashield’s customers, suppliers, competitors and employees in all business dealings on Equashield’s behalf. Company Representatives should not take unfair advantage of another person in business dealings on Equashield’s behalf through the abuse of privileged or Confidential Information or through improper manipulation, concealment or misrepresentation of material facts. Equashield’s policy is to comply with all applicable antitrust and fair trade laws. Any questions about whether a specific practice violates antitrust and fair competition laws should be directed to the relevant superiors.
2.3 Trade compliance
Equashield complies with relevant export controls and sanctions laws. Employees never attempt to circumvent applicable trade sanctions.
2.4 Accuracy of Records, Anti-money laundering
The integrity, reliability and accuracy in all material respects of Equashield’s books, records and financial statements is fundamental to Equashield’s continued and future business success. All of Equashield’s books, records, accounts and financial statements must be maintained in reasonable detail, must appropriately reflect Equashield’s transactions and must conform both to applicable legal requirements and to Equashield’s system of internal controls. Company Representatives may not create any false or artificial documentation or book entry for any transaction entered into by Equashield. Company Representatives carry out all deals and financial activity with complete transparency and in line with standard processes, and report any suspicious transactions.
2.5 Conflicts of interest
Equashield recognizes and respects the right of Company Representatives to engage in activities outside of a business relationship with Equashield, provided that these activities do not impair or interfere with the performance of their duties to Equashield or their ability to act in Equashield’s best interests. In most, if not all, cases this will mean that Company Representatives must avoid situations that present a potential or actual conflict between their personal interests and Equashield’s interests.
A “conflict of interest” occurs when the personal interest of a Company Representative interferes with Equashield’s interests. Conflicts of interest may arise in many situations. For example, conflicts of interest can arise when an employee takes an action or has outside interests, responsibilities or obligations that may make it difficult to perform the responsibilities of his or her position objectively and/or effectively in Equashield’s best interests. Conflicts of interest may also occur when a Company Representative or his/her immediate family member receives some personal benefit (whether improper or not) as a result of his/her position with Equashield. Each individual’s situation is different and in evaluating his or her own situation, Company Representatives will have to consider many factors.
Company Representatives owe a duty to Equashield to advance its legitimate business interests when the opportunity to do so arises. Appropriating for a Company Representative’s direct or indirect personal benefit, or diverting to others, a business opportunity in which Equashield might reasonably be expected to be interested, without first making the opportunity available to Equashield, is prohibited. Additionally, any Company Representative diverting to himself or herself or to others any opportunities that are discovered through the use of Equashield’s property or information or as a result of his or her position with Equashield, using Equashield’s property or information or his or her position for improper personal gain, or competing with Equashield, is prohibited.
We declare any actual or potential conflict of interest situations to relevant superiors so that it can be solved.
2.6 Inside information and confidential information
Confidential Information generated and gathered in Equashield’s business plays a vital role in Equashield’s business, prospects and ability to compete. “Confidential information” includes all non-public information that might be of use to competitors or harmful to Equashield or its customers if disclosed. Company Representatives must use appropriate judgment when disclosing any proprietary or Confidential Information to other Company Representatives, and such disclosure should only be on a legitimate “need to know” basis. Company Representatives may not disclose or distribute Equashield’s Confidential Information to third parties, except when disclosure is authorized by Equashield or required by applicable law, rule or regulation or pursuant to an applicable legal proceeding. Prior to making any external disclosure, even if required by applicable law, rule or regulation or pursuant to an applicable legal proceeding, Company Representatives must notify the relevant superiors of any pending disclosure so that Equashield may take any available legal action to protect its Confidential Information to the extent possible. Company Representatives shall use Confidential Information solely for legitimate company purposes. All information received from the Company are handled in a secure and confidential manner according to applicable confidentiality undertakings.
In addition, information provided to Company Representatives in good faith with an expectation of confidentiality by our customers and suppliers or other third parties must be treated with the same degree of confidentiality.
2.7 Communications and social media
Equashield’s external communications are accurate, transparent, and straightforward. When using social media, Company Representatives avoid giving the impression that they are speaking on behalf of the Company, unless they are authorised to do so.
2.8 Interactions with Healthcare Professionals
Equashield is firmly committed to complying with all laws and regulations governing its interactions with Healthcare Professionals.
Equashield will conduct its business in compliance with all applicable laws and regulations governing the manufacture, labelling, and distribution of Equashield’s products. Company Representatives are required to adhere to established Company quality standards and quality control/quality assurance procedures. Company Representatives who are aware of any deviations from the Company’s established quality standards and procedures, whether intentional or accidental, must immediately bring these deviations to the attention of their supervisor.
Company Representatives may come in contact with confidential patient information or individually identifiable health information in the performance of their job duties. Confidential patient information or individually identifiable health information must be carefully safe-guarded. Company Representatives must always strictly adhere to laws and rules relating to protecting confidential patient information.
2.9 Relationship with suppliers and other business partners
Where relevant, Equashield performs risk based due diligence on potential suppliers and other business partners before we enter into business relationships. We exercise fair behaviour with suppliers, including taking measures to prevent late payments.
3. HUMAN RIGHTS AND LABOUR STANDARDS
3.1 Human rights
Equashield considers respect for human rights to be a minimum standard for conducting business with legitimacy. To this end, we commit to respect the UN Guiding Principles on Business and Human Rights and we recognise our responsibility to conduct our business with respect for all internationally recognised human rights. We are committed to identify instances where our business could cause or contribute to adverse human rights impacts and, as effectively as possible, to prevent, neutralise and mitigate any such impact(s) and, if necessary, provide remediation to affected persons.
3.2 Modern slavery and children’s rights
Equashield does not tolerate any forms of modern slavery, including forced, bonded or compulsory labour, or human trafficking. We respect children’s right to personal development and education, and do not employ persons under the legally prescribed minimum age.
3.3 Healthy and safe working environment
Equashield strives to provide a safe and healthful work environment. Protecting the safety of our employees and visitors is the most important aspect of running our business. Each employee is expected to obey safety rules and to exercise caution in all work activities. Employees must immediately report any unsafe condition to any member of management.
3.4 Diversity, equity and inclusion
Equashield is firmly committed to providing equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment of any kind. Equashield will offer opportunities for employment, training, development and promotion to qualified individuals without regard to race, religion, national origin, color, sex, sexual orientation, age, military status, citizenship, disability or any other characteristic protected by law. Discrimination or harassment is not tolerated. Any form of physical, sexual, or psychological harassment or abuse is strictly prohibited.
3.5 Privacy and personal data
We safeguard and take steps to protect the privacy of our employees, customers and others. This includes complying with applicable laws when we process personal data. Personal data is disclosed to third parties only when legitimate grounds to do so have been established and appropriate measures have been taken to protect the information to be transferred.
4. ENVIRONMENTAL SUSTAINABILITY
Equashield conducts business in compliance with applicable environmental laws and regulations and integrates sustainability considerations into the Company’s business strategy and value creation plans.
We recognize that climate change mitigation and climate change adaptation are fundamental for any companies long-term business success. We continuously strive to ensure that our operations are conducted with the least possible negative impact on the environment, climate, water, biodiversity and ecosystems. In our day-to-day operations, we assume environmental responsibility and, as much as possible, we try to reduce the impact it has on services, products and raw materials used by our Company.
5. IMPLEMENTATION, COMPLIANCE AND ENFORCEMENT
The Code has been adopted by Equashield’s Board of Directors. It is the personal responsibility of every Company Representatives to understand and comply with the Code. Managers should ensure that their subordinates fully understand and comply with the standards and requirements stipulated in the Code.
The Company provides adequate training on the Code for all employees, consistent with the Company’s risk profile and appropriate to employee responsibilities.
We do not tolerate illegal or unethical behaviour. Suspicions of violations of this Code including business conduct incidents, will be investigated promptly, independently and objectively. Anyone violating the Code may be subject to disciplinary action, up to and including termination of employment.
6. REPORTING
We encourage an environment with an open-door policy for reporting suspected violations of this Code to Ms. Tal Weiss, VP HR and Ethics Officer of Equashield, preferring that Company Representatives identify themselves to facilitate Equashield’s ability to address the report, including conducting any necessary investigation. If a Company Representative chooses anonymity, Equashield will endeavour to protect their confidentiality within legal bounds, though this may limit the thoroughness of any subsequent investigation due to lack of information; thus, anonymous reporters are encouraged to provide sufficient detail for Equashield to assess and potentially investigate the allegations.
Equashield expressly forbids any retaliation against any Company Representative who, acting in good faith, reports suspected misconduct. Any Company Representative who participates in any such retaliation is subject to disciplinary action, including termination.
