Anti-Corruption Policy

"NAIRI" Medical Center
Anti-Corruption Policy Rules

This Anti-Corruption Policy of "Nairi" Medical Center is an official document that establishes clear rules for the prevention of unlawful remuneration, bribery, and conflicts of interest by members of the medical staff.

1. Main Objectives of the Policy

Prevention: Exclude any form of corruption and sponsorship.
Transparency: Ensure clear and accessible pricing for medical services.
Trust: Increase patients’ trust in the medical institution.
Legality: Ensure full compliance with the anti-corruption legislation of the Republic of Armenia.

2. Risk Areas in Medical Institutions

Illegal Payments: Requesting “treats” or bribes from patients or their relatives.
Pharmaceutical Companies: Prescribing medications of specific brands by physicians in exchange for additional incentives.
Procurement Process: Conducting non-transparent tenders for medical equipment or pharmaceuticals.
State-Funded Healthcare Programs: Illegal or biased allocation of free healthcare services covered by the state.

3. Main Prevention Mechanisms

Restriction on Gifts: Medical personnel are prohibited from accepting monetary or valuable gifts.
Whistleblowing System: An anonymous reporting box or hotline is established in the hospital for reporting cases of misconduct or abuse.
Ethics Committee: An internal body is established to review corruption risks and complaints.
Training: Regular anti-corruption conduct training sessions are conducted for staff members.
Electronic Systems: Implementation of online appointment scheduling and payment systems (to reduce the impact of human factors).

4. Liability Measures

Disciplinary Measures: Warning, formal reprimand, or termination of the employment contract.
Legal Measures: Transfer of relevant documents to law enforcement authorities for the purpose of initiating criminal liability proceedings.

These Rules include the following three components: the official rules of the anti-corruption policy, the provisions of the Medical Code of Ethics, and the legal restrictions on the acceptance of gifts, aligned with the legislation of the Republic of Armenia (Government Decision No. 182-N of the Republic of Armenia and the Law "On Public Service").

PART 1. ANTI-CORRUPTION POLICY
INTERNAL ANTI-CORRUPTION POLICY OF "NAIRI" MEDICAL CENTER

1. General Provisions

Purpose: This document establishes the main principles for the prevention, detection, and elimination of corruption-related practices within the Medical Center (hereinafter referred to as the "MC").
Scope of Application: This Policy is mandatory for all employees of the MC, regardless of their position held (management, physicians, nursing and junior medical staff, and administrative employees).
Zero Tolerance: The MC adopts a zero-tolerance approach toward any form of corruption, bribery, and abuse of official position.

2. Prohibited Activities

Direct and Indirect Bribery: It is prohibited to request, expect, or receive any material or non-material benefit (money, gifts, services) from patients, their relatives, or third parties in exchange for properly providing or expediting medical care available at the MC.
Illegal Cooperation: It is prohibited to receive personal financial kickbacks from pharmaceutical companies or medical equipment suppliers in exchange for promoting or requiring the use of specific medicines or services.
Misuse of State-Funded Healthcare Services: It is prohibited to artificially delay state-funded (government-covered) free or preferential medical services or to demand additional unofficial payments for such services.

3. Whistleblowing System and Confidentiality

Reporting: Any employee or patient who has witnessed a corruption-related incident is required to report it to the MC’s Anti-Corruption Officer or use the anonymous hotline/reporting box.
Guarantee of Anonymity: The MC guarantees the confidentiality of the whistleblower’s information and prohibits any retaliation or workplace discrimination against the person who submitted the report.

PART 2. CODE OF MEDICAL ETHICS

(Aligned with the professional ethics rules for healthcare workers approved by Government Decision No. 182-N of the Republic of Armenia)

1. Healthcare Worker–Patient Relations

Dignity: A physician is obligated to respect the patient’s dignity, right to self-determination, and provide equal treatment regardless of the patient’s social status, financial situation, or nationality.
Informed Consent: A physician is obligated to explain to the patient, in an accessible manner, their health condition, proposed treatment methods, and possible risks.
Medical Confidentiality: Any information regarding a patient’s health, private life, and examination results constitutes medical confidentiality and may not be disclosed to third parties without the patient’s consent (except in cases established by law).

2. Professional Independence and Conflict of Interest

Independence: A physician’s professional decisions (such as prescribing medications or determining the necessity of surgery) must be based exclusively on evidence-based medicine and the best interests of the patient.
Prevention of Conflicts of Interest: Physicians are prohibited from engaging in activities where their personal financial interests conflict with the patient’s health interests (for example, referring a patient to a specific paid laboratory in order to receive a commission or percentage from that laboratory).

3. Collegial Relationships

Collegiality: Healthcare workers must demonstrate respect and provide mutual support to one another. It is prohibited to criticize or discredit a colleague’s professional qualifications in the presence of a patient.

PART 3. LEGAL RESTRICTIONS ON THE ACCEPTANCE OF GIFTS

(Pursuant to Article 29 of the Law of the Republic of Armenia "On Public Service" and integrity principles applicable to state and community-owned medical centers)

1. What Is Considered a "Gift"

A gift is considered any property-related benefit, including money, gold jewelry, free services, discounts, or forgiveness of obligations, provided to a healthcare worker in connection with the performance of their official duties.

2. Prohibited and Permissible Gifts

Gift Type	Status	Conditions and Limits
Cash Funds (Cash, Bank Transfer)	Strictly Prohibited	Any amount of money, regardless of its value, is considered a bribe or unlawful remuneration.
Flowers, Sweets (Symbolic Appreciation)	Permitted	Allowed if they are purely ceremonial expressions of gratitude/respect and do not influence the physician’s objectivity.
Official Gifts (Conferences, Souvenirs)	Permitted	Standard gifts provided during official delegations or scientific conferences (such as pens, notebooks, and similar items).

3. Value Limits and Record-Keeping

Single-Occasion Limit: The value of a permissible ceremonial gift must not exceed 40,000 Armenian drams (AMD) (or the current maximum amount established by law).
Annual Limit: The total value of permissible gifts received from the same person during a calendar year must not exceed 60,000 Armenian drams (AMD).
Gift Register: If the value of an allowable official gift exceeds the established limit, the healthcare worker is required to transfer it to the MC administration as the property of the organization and record it in the internal gift register.

Appendix 1

PART 1. INTERNAL WHISTLEBLOWING (COMPLAINT) PROCEDURE

1. Reporting Channels

The following channels are available at the MC for reporting corruption risks or violations:

Email Address: [email protected]; [email protected] (accessible only to the Anti-Corruption Officer).
Telephone Number / Hotline: +374 (95) 200095 (with call recording capability).
Physical Box: Located on the first floor of the hospital, outside the field of view of surveillance cameras, for anonymous written reports.

2. Stages of Report Review

Registration: The submitted complaint is recorded in the internal register within 24 hours (if the report is anonymous, the author field is filled in as "Anonymous").
Preliminary Review: The Ethics and Anti-Corruption Committee determines the credibility of the report within 5 working days.
Internal Investigation: If the facts are confirmed, an investigation procedure is initiated, and the parties involved are heard (except in cases involving an anonymous whistleblower).
Decision: A recommendation is submitted to the administration regarding the application of disciplinary measures or the transfer of materials to law enforcement authorities.

Appendix 2

PART 2. ANNUAL CONFLICT OF INTEREST DECLARATION (TEMPLATE)

DECLARATION OF AN EMPLOYEE OF "NAIRI" MEDICAL CENTER

I, ____________________________________________________________________
(Full Name)

Position held: ___________________________________________________________

Department: _____________________________________________________________

Hereby confirm that I have familiarized myself with the Anti-Corruption Policy of the MC and declare the following:

1. Relationship with Pharmaceutical Companies (Select as applicable):

☐ Me or my family members have no financial interests, and we do not receive honoraria or sponsorship from any pharmaceutical or medical company.

☐ I have the following potential conflict of interest (please specify the company and the nature of the conflict):

2. Other Employment Activities

☐ I do not work and do not provide consulting services to other competing or affiliated medical institutions operating outside the MC.

☐ I work concurrently at: ____________________________________

3. Commitment

I undertake to perform my professional duties guided exclusively by the best interests of the patient and to immediately notify the administration in the event of any external financial influence or potential conflict of interest.

Date: "__" ___________ 202
Signature: _________________

Appendix 3

PART 3. PATIENT INFORMATION POSTER TEXT

DEAR PATIENTS AND RELATIVES,

Our Medical Center operates a "ZERO BRIBERY" and "ZERO CORRUPTION" policy.

All payments (for examinations, surgeries, consultations) must be made EXCLUSIVELY AT THE HOSPITAL CASH DESK OR VIA TERMINAL. Please request your fiscal receipt.
Medical personnel are prohibited from requesting or accepting any additional payments, "treats” or valuable gifts in cash.
For patients receiving treatment within the framework of state-funded healthcare programs, all included services are provided COMPLETELY FREE OF CHARGE.

If you are asked to make a payment or have witnessed any misconduct:

Immediately call the Hotline: +374 (93) 667061 or submit a report using the Anonymous Reporting Box located below.

Your report will help improve the quality of medical services and prevent unlawful practices.

Appendix 4

PART 1. PRACTICAL STEPS FOR IMPLEMENTING THE INTERNAL WHISTLEBLOWING (COMPLAINT) PROCEDURE

To ensure the proper implementation of the whistleblowing system and to avoid legal issues, the following mechanisms must be established:

1. Protection of the Whistleblower (Complete Anonymity)

Exclusion of Cameras: The physical box for anonymous complaints must be placed in a corridor or area where there are no hospital security cameras.

Digital Security: The email address ([email protected]; [email protected] ) must have two-factor authentication (2FA) enabled. Access rights must be granted exclusively to the Anti-Corruption Officer (or the Chairperson of the Ethics Committee).

2. Timeline and Stages of the Internal Investigation

Day 1: Receipt and registration of the report/alert in a specially coded register (for example, NMC-GT-001).

Days 2–3: Preliminary screening. If the complaint is not supported by factual evidence or contains only personal insults, it is archived.

Days 4–7: Evidence collection. The Committee reviews the relevant patient’s electronic medical record, cash register records, and physician prescriptions.

Days 8–10: Hearing stage. A written explanation is obtained from the healthcare worker.

Days 11–12: Preparation of the final summary and submission of the report to the General Director of the hospital.

PART 2. ENHANCED CONFLICT OF INTEREST PREVENTION

In addition to completing the annual conflict of interest declaration, the following two key risks must be eliminated within the hospital:

1. Restriction on Access of Pharmaceutical Company Representatives (Medical Reps)

Restriction on Visits: Representatives of pharmaceutical companies are prohibited from walking through hospital departments during working hours and from having individual meetings with physicians.

Authorized Platform: Presentations of medicines or medical innovations may be conducted only with the permission of the hospital administration and exclusively in the format of general scientific seminars or conferences attended by all physicians simultaneously.

Prescription Monitoring: The administration regularly conducts random monitoring of prescriptions. If it is identified that a physician prescribes exclusively one brand of expensive medication to patients (when more affordable generic alternatives are available), an internal investigation is initiated.

2. Prohibition on Referrals to Affiliated Clinics and Laboratories

Priority of Internal Resources: If the hospital has its own laboratory or CT /MRI equipment, physicians are prohibited from referring patients to other private centers for personal financial benefit (such as the expectation of receiving commissions or percentages).

Mandatory Justification: If a patient must nevertheless be referred to another clinic (for example, when the required examination is not available at the hospital), the physician is required to provide a written justification in the patient’s medical record explaining why that particular center was selected.

Appendix 5

TEMPLATE OF THE ORDER OF THE DIRECTOR OF THE MEDICAL CENTER

"__________NAIRI__________" MEDICAL CENTER

No. _____ORDER OF THE GENERAL DIRECTOR

"__" _______________ 202_
Yerevan

ON APPROVING THE ANTI-CORRUPTION POLICY, WHISTLEBLOWING PROCEDURE, AND CONFLICT OF INTEREST PREVENTION RULES AT THE MEDICAL CENTER

Guided by the relevant provisions of the Labor Code of the Republic of Armenia, the Law of the Republic of Armenia "On the Whistleblowing System", Government Decision No. 182-N of the Republic of Armenia, and based on the necessity to ensure transparency, legality, and integrity in the services provided by the Medical Center,

I HEREBY ORDER:

1. To approve and put into effect the following package of internal anti-corruption regulations of "NAIRI" Medical Center (hereinafter referred to as the MC):

Appendix 1: Anti-Corruption Policy and Code of Medical Ethics.

Appendix 2: Internal Whistleblowing (Complaint) Procedure and Whistleblower Protection Mechanisms.

Appendix 3: Conflict of Interest Prevention Rules and Annual Declaration Form.

2. To appoint the Director of the MC, Narine Mamikonyan, as the Anti-Corruption Officer (or Chairperson of the Ethics Committee).

To ensure that the responsible person maintains the proper availability and confidentiality of the anonymous complaint box, hotline, and email address.

3. To the Human Resources Management (HR) Department:

To ensure that all employees of the MC (physicians, nurses, senior nurses, and administrative staff) are familiarized with the content of this Order and its related appendices by signature within 5 working days.
To ensure that all medical employees complete the Annual Conflict of Interest Declaration and that it is attached to their personnel files.
To include a mandatory requirement for compliance with anti-corruption rules in the employment contracts of newly hired employees.

4. To the Information Technology (IT) and Marketing Departments:

To publish the patient information posters on the official website of the MC and in visible locations, including the hotline telephone number and email address.

5. Failure to comply with or violation of the requirements of this Order shall constitute a serious breach of labor discipline and shall result in disciplinary and legal liability in accordance with the procedure established by the legislation of the Republic of Armenia.

6. I reserve control over the implementation of this Order.

7. This Order shall enter into force from the moment of its signing.

GENERAL DIRECTOR: Narine Mamikonyan