CODE OF CONDUCT

ARETION & Company and its Subsidiaries

 OPENING MESSAGE: OUR COMMITMENT TO INTEGRITY

ARETION & Company and its subsidiaries—ARETION Informatics Solutions, ARETION Publishing Group, and ARETION Healthcare Consulting—are committed to the highest standards of ethical conduct, professional integrity, and legal compliance.

This Code of Conduct reflects our promise to our clients, patients, partners, employees, and the public that we will:

– Act with honesty and transparency in all dealings;

– Prioritise patient safety and wellbeing in all advice and recommendations;

– Provide independent, objective, evidence-based guidance free from conflicts of interest;

– Comply strictly with applicable laws and regulations;

– Respect human rights, dignity, and equality;

– Operate sustainably and responsibly;

– Speak up about misconduct without fear of retaliation.

This Code applies to everyone who works for or represents ARETION & Company and its subsidiaries—employees, officers, contractors, partners, and agents. We believe that ethical business conduct and strong governance are essential to earning trust and delivering value.

We are accountable to our stakeholders, regulators, and the public. We welcome scrutiny of our conduct and are committed to continuous improvement.

 TABLE OF CONTENTS

1. Purpose, Scope, and Applicability
2. Core Values and Ethical Principles
3. Compliance with Laws, Regulations, and Professional Standards
4. Anti-Bribery and Anti-Corruption
5. Conflicts of Interest
6. Confidentiality, Data Protection, and Information Security
7. Professional Conduct with Clients and Protection of Patients’ Interests
8. Fair Treatment, Diversity, Equity, Inclusion, and Anti-Harassment
9. Human Rights, Modern Slavery, and Responsible Supply Chain
10. Health, Safety, and Wellbeing at Work
11. Use of Company Assets, Technology, Intellectual Property, and Acceptable Use
12. Insider Information, Market Abuse, and Handling Sensitive Commercial Information
13. Research Ethics, Data Analytics, and AI/Algorithmic Fairness
14. Environmental and Social Responsibility
15. Record-Keeping, Documentation, and Reporting Accuracy
16. Speaking Up, Whistleblowing, and Non-Retaliation
17. Responsibilities of Managers and Leaders
18. Monitoring, Accountability, and Consequences of Breaches
19. Acknowledgement and Annual Reaffirmation

1. PURPOSE, SCOPE, AND APPLICABILITY

1.1 Purpose

This Code of Conduct sets out the standards of ethical behaviour, professional integrity, and legal compliance that ARETION & Company and its subsidiaries are committed to upholding. It serves as a public statement of our values and expectations, and provides guidance to our employees, contractors, partners, clients, and stakeholders about how we conduct our business.

1.2 Who This Code Applies To

This Code applies to:

– All employees of ARETION & Company and its subsidiaries (full-time, part-time, fixed-term, and temporary);

– Officers, directors, and members of boards;

– Partners, joint venture participants, and affiliates;

– Contractors, consultants, secondees, and agency workers;

– Anyone representing ARETION & Company or its subsidiaries in any capacity.

Non-compliance by any individual is a serious matter and will result in appropriate action, including disciplinary measures and, where necessary, referral to law enforcement or regulators.

1.3 Our Group Structure

ARETION & Company operates through three principal subsidiaries:

– ARETION Informatics Solutions – providing health information technology, digital solutions, data platforms, data analytics, and technology-enabled consulting to healthcare organisations;

– ARETION Publishing Group – producing healthcare publications, research, evidence synthesis, policy analysis, and knowledge dissemination to advance healthcare practice and policy;

– ARETION Healthcare Consulting – delivering strategy consulting, operational improvement, workforce development, clinical pathway redesign, digital health implementation, and advisory services to healthcare providers, commissioners, and systems.

This Code applies uniformly across all subsidiaries. All employees and contractors, regardless of which subsidiary employs them, must comply with this Code in full.

1.4 International Applicability

ARETION & Company operates internationally and works across multiple jurisdictions. This Code sets a consistent baseline of ethical standards across our global operations. We also comply strictly with:

– The laws and regulations of the United Kingdom (where we are headquartered);

– The laws, regulations, and professional standards of each country where we operate or where our employees work;

– Client-specific and sectoral compliance requirements.

Where local law is stricter than this Code, we comply with local law. Our commitment to ethical conduct does not change based on geography or local custom.

1.5 Supporting Policies

This Code is supported by detailed policies available to employees on our internal systems. For clients, partners, and external stakeholders with questions about our policies, please contact compliance@aretion.co.uk or see Section 16 (Speaking Up and Whistleblowing) for contact details.

Key supporting areas include:

– Anti-Bribery and Corruption

– Data Protection and Privacy

– Conflicts of Interest Management

– Information Security

– Health and Safety

– Whistleblowing and Concerns Reporting

– Modern Slavery and Responsible Sourcing

– Environmental Responsibility

– Research Ethics and Data Analytics

2. CORE VALUES AND ETHICAL PRINCIPLES

2.1 Our Core Values

ARETION & Company and its subsidiaries operate according to seven core values:

 Integrity

We act with honesty, fairness, and transparency in all our dealings. We keep our commitments, acknowledge mistakes, and are accountable for our actions. We refuse to compromise on ethical standards regardless of commercial pressure, client preferences, or financial incentive. Our reputation is built on doing the right thing, even when it is difficult or costly.

 Patient-Centred Impact

Healthcare is our business. Everything we do—whether we advise on digital systems, publish research, or redesign clinical pathways—must ultimately benefit patients and improve health outcomes. We prioritise patient safety, dignity, equity, and access to care in all recommendations. We challenge any proposal that could harm patients or communities without clear ethical justification and proper safeguards.

 Independence and Objectivity

We provide impartial, evidence-based advice. We do not allow conflicts of interest, personal relationships, financial ties, or client preferences to compromise our professional judgment. We conduct research and analysis based on evidence and rigorous methodology, not ideology or commercial interest. We will give uncomfortable advice, challenge assumptions, and recommend unpopular actions when evidence and ethics demand it. Our value to clients lies in our independence.

 Respect

We value the dignity, rights, autonomy, and wellbeing of everyone we work with—colleagues, clients, patients, and communities. We treat all people fairly, regardless of background, role, gender identity, disability, ethnicity, religion, sexual orientation, or any other characteristic. We listen, collaborate, and create an inclusive environment where diverse perspectives are welcomed and valued.

 Accountability

We take responsibility for the quality and integrity of our work, the accuracy of our analysis, and the impact of our projects. We are transparent about what we can deliver, what we cannot, and the limitations of our expertise. We meet our commitments, explain our decisions clearly, and welcome scrutiny. We report on our performance and take action to address shortfalls.

 Sustainability

We consider the long-term environmental and social impact of our work. We support clients in building resilient, sustainable health systems that serve future generations responsibly. We operate our own business sustainably, minimising environmental impact, and contribute positively to the communities where we work.

 Transparency

We communicate openly and honestly with clients, regulators, employees, and the public. We disclose our interests, explain our methods and limitations, acknowledge our conflicts, and provide accurate information. We do not hide or conceal material facts.

2.2 Ethical Principles

In addition to our core values, we follow these ethical principles:

– Legality: We comply with all applicable laws and regulations. This is non-negotiable.

– Honesty: We do not deceive, mislead, or conceal material facts. We provide accurate information and correct errors promptly.

– Respect for persons: We respect human rights, dignity, autonomy, and privacy. We recognise the right of individuals to make informed decisions about their care and their data.

– Fairness and equity: We treat people equitably and actively work to address discrimination and health inequalities. We recognise that healthcare is not equally accessible to all and consider equity in our work.

– Responsibility: We consider the impact of our actions on patients, colleagues, clients, communities, and society. We do not pursue commercial gain at the expense of ethics or public welfare.

3. COMPLIANCE WITH LAWS, REGULATIONS, AND PROFESSIONAL STANDARDS

3.1 Legal Compliance Commitment

ARETION & Company and its subsidiaries are committed to strict compliance with all applicable laws and regulations. These include, but are not limited to:

– Anti-corruption: Bribery Act 2010

– Data protection and privacy: UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018

– Human rights: Modern Slavery Act 2015, Human Rights Act 1998

– Equality and discrimination: Equality Act 2010

– Health and safety: Health and Safety at Work etc. Act 1974 and related regulations

– Healthcare regulation: Applicable healthcare laws and regulations in each jurisdiction where we operate

– Employment law: Employment Rights Act 1996 and related employment legislation

– Environmental law: Environmental Protection Act 1990 and climate/sustainability regulations

– Intellectual property: Copyright, Designs and Patents Act 1988

– Company law: Companies Act 2006

– Competition law: Competition Act 1998, Enterprise Act 2002

– Client-specific regulations: Financial services, public sector, regulated industry requirements

3.2 Professional Standards

Many of our employees hold professional qualifications or registrations (doctors, nurses, health professionals, researchers, chartered managers, engineers, etc.). We expect all professionals to comply with the codes of practice and standards of their professional bodies and to maintain their registrations and credentials.

If your professional registration is under investigation, suspended, or subject to conditions, you must inform your manager and HR immediately.

3.3 Breach of Law

Breaches of law are serious and may result in:

– Criminal prosecution and imprisonment of individuals;

– Civil liability and financial penalties;

– Disciplinary action by ARETION & Company, including dismissal;

– Referral to professional regulators or law enforcement;

– Exclusion from future contracts and debarment from public sector work;

– Reputational damage to you and to ARETION & Company.

We will fully cooperate with law enforcement, regulatory investigations, and judicial proceedings.

3.4 If You Are Unsure

If you are uncertain about whether something is lawful or complies with this Code, do not proceed. Instead:

– Ask your manager or team leader;

– Contact our Compliance and Ethics team: compliance@aretion.co.uk;

– Consult the relevant internal team (HR, Finance, Legal, Information Security);

– Seek independent legal advice if necessary.

We will not penalise anyone for raising a good-faith question about legal compliance. We expect and welcome such questions.

4. ANTI-BRIBERY AND ANTI-CORRUPTION

4.1 Zero-Tolerance Policy

ARETION & Company and its subsidiaries have a zero-tolerance policy on bribery and corruption. The UK Bribery Act 2010 makes bribery a serious crime. Non-compliance could result in criminal prosecution of individuals, corporate criminal liability, substantial fines, and loss of business.

We do not tolerate bribery in any form, whether offered by us, to us, or by anyone acting on our behalf.

4.2 What Is Bribery?

Bribery is the offer, promise, or giving of an advantage (financial or non-financial) with the intention of:

– Inducing someone to perform an improper function; or

– Rewarding them for having done so.

The advantage can be anything of value: money, gifts, hospitality, services, contracts, donations, opportunities, or preferential treatment.

The recipient can be a client, government official, healthcare regulator, procurement officer, supplier, or anyone else.

It does not matter whether:

– The advantage was actually given or accepted;

– The intended function was actually performed;

– You personally benefited or acted for ARETION;

– There was a formal agreement.

If the intention is to influence improperly, it is bribery.

4.3 Examples

Clearly prohibited:

– Offering cash or a cheque to a government health official to secure a contract.

– Promising a hospital board member a consulting contract in return for awarding us a tender.

– Donating to a hospital charity specifically to secure work from that hospital.

– Giving expensive gifts or hospitality to a procurement officer who influences contract decisions.

– Arranging a lucrative consulting job for a client official’s family member to secure business.

Acceptable:

– A modest gift (under £50) to a long-standing contact on a personal occasion (retirement), provided it is not linked to a pending business decision.

– Paying for a client representative’s conference attendance where multiple professionals are invited.

– A working business lunch to discuss a proposal, with reasonable costs and transparent billing.

– Providing educational materials or training to healthcare professionals (if offered transparently to all relevant professionals, not targeted at specific decision-makers).

If you are unsure, do not do it. Ask the Compliance and Ethics team: compliance@aretion.co.uk

4.4 Gifts and Hospitality

We may provide modest gifts or reasonable business hospitality, provided:

– The value is modest (typically under £50 per gift);

– It is not cash or a bank transfer;

– It is not connected to a pending business decision or contract;

– It is not given with expectation of obtaining a business benefit;

– It is transparent and recorded;

– It is not given to government officials without prior written approval;

– It is reasonable and proportionate (not lavish or unusual);

– It does not create a perception of impropriety.

All gifts given by ARETION & Company representatives are recorded in a Gifts Register maintained by local managers.

4.5 Dealings with Government Officials and Public Bodies

Government officials, healthcare regulators, commissioners, and public sector procurement officers are subject to heightened restrictions. We are particularly careful in dealing with public officials because:

– Public funds must be used responsibly;

– Public officials must be seen to be impartial;

– Bribery of public officials is taken especially seriously by law enforcement.

We do not offer gifts, hospitality, or favours to government officials unless:

– Prior written approval has been obtained from the Compliance and Ethics team;

– The gift or hospitality is genuinely modest and complies with this Code;

– It is transparent and recorded.

4.6 Facilitation Payments

A “facilitation payment” is a small payment offered to a government official to speed up a routine administrative action (e.g. to expedite a visa, permit, or application). Facilitation payments are prohibited under UK law and our policy. If anyone requests a facilitation payment, refuse and report it to us immediately at compliance@aretion.co.uk.

4.7 Third-Party Intermediaries

We work with agents, partners, suppliers, and subcontractors. We are responsible for their conduct. We ensure that:

– Intermediaries are properly vetted before engagement;

– Anti-bribery and corruption clauses are included in all contracts;

– Intermediaries are required to comply with this Code;

– We do not use intermediaries to conduct activities that would be unlawful if we performed them directly;

– We investigate and take action if we become aware of improper conduct.

4.8 If You Suspect Bribery or Corruption

If you suspect bribery, corruption, or an improper offer:

– Do not engage with the offer or make any payment;

– Do not discuss it unnecessarily with colleagues;

– Report immediately to your manager, HR, or the Compliance and Ethics team;

– Contact our external Whistleblowing Hotline (see Section 16);

– Keep records of what happened (dates, names, communications).

Reporting suspected bribery will not result in retaliation or disciplinary action against you, provided you report in good faith.

5. CONFLICTS OF INTEREST

5.1 Our Commitment

ARETION & Company is committed to identifying, disclosing, and managing conflicts of interest fairly and transparently. A conflict of interest arises where your personal or financial interests, relationships, or commitments could, or could be perceived to, influence your professional judgment or create a breach of duty to ARETION & Company or our clients.

Conflicts are common in professional life and are not necessarily prohibited. However, they must be disclosed and properly managed.

5.2 Types of Conflicts

Financial conflicts:

– Ownership of shares or financial interest in a client, competitor, or supplier;

– Receipt of personal payment, commission, or financial benefit from a third party connected to our work;

– Significant personal debt or financial distress;

– Financial interest in a company or technology that we recommend to clients;

– Investment portfolios that could be affected by advice we give;

– Loans or financial arrangements with colleagues or clients.

Relational conflicts:

– Family relationships (spouse, partner, parent, child, sibling) with clients, competitors, suppliers, or colleagues in senior positions;

– Close personal friendships or relationships that could influence professional judgment;

– Previous close working relationships with clients or their representatives;

– Mentoring or sponsorship relationships that could create bias.

Professional conflicts:

– Outside employment, consultancy, or business interests with clients or competitors;

– Board positions, trustee roles, or advisory positions with organisations that could conflict with ARETION’s interests;

– Simultaneous advice to competing clients on related matters;

– Research or publication interests that could be influenced by commercial relationships.

Reputational conflicts:

– Association with controversial organisations, individuals, or causes;

– Previous employment or relationships that could create a perception of bias;

– Public statements or affiliations that could undermine perceived objectivity.

5.3 Your Obligation to Disclose

You must disclose any actual or potential conflict of interest:

– At recruitment: During the hiring process, you will be asked about potential conflicts.

– Before joining a project: If you have or become aware of a conflict relevant to a new project or client, disclose it immediately.

– As soon as you become aware: If circumstances change and a new conflict arises during your employment, disclose it without delay.

– Upon request: If asked by your manager or Compliance team about potential conflicts, answer honestly and completely.

Disclosure is not admission of wrongdoing. Failure to disclose is a serious breach.

5.4 How We Manage Conflicts

Once a conflict is disclosed, we will assess it and take one or more of the following steps:

No action required: If the conflict is minimal or can be quickly resolved (e.g. a minor family connection with no influence on work), we may approve it with no further steps.

Managed arrangement: We may approve the conflict with agreed management steps, such as:

– Removing you from involvement in the matter or decision;

– Implementing information barriers (you do not see confidential information from competing clients);

– Obtaining informed written consent from affected clients;

– Having an independent colleague review or oversee your work;

– Regular monitoring and reassessment.

Divest or step down: We may ask you to:

– Sell a financial holding or investment;

– Resign from an outside board or advisory role;

– Terminate an outside business interest.

Unable to manage: In cases of serious, irreconcilable conflict, we may decide that the conflict cannot be appropriately managed and may:

– Reassign you to different work;

– Decline to take on work due to the conflict;

– In cases of serious misconduct (concealment of conflict), take disciplinary action.

5.5 Client and Commercial Conflicts

Healthcare consulting often involves situations where we advise multiple organisations in the same sector or with competing interests. This is acceptable provided we:

– Identify conflicts early;

– Obtain informed written consent from affected clients;

– Implement information barriers to protect confidential information;

– Are transparent about any financial interests in recommended solutions or technologies;

– Do not use confidential information from one client to benefit another.

5.6 Outside Employment and Activities

Before undertaking any outside employment, paid consultancy, business venture, board position, trustee role, or significant voluntary commitment, you must obtain written permission from your manager. Permission will normally be refused if the outside activity:

– Conflicts with your duties to ARETION;

– Involves a client, competitor, or supplier;

– Involves a government agency or regulator that we work with;

– Takes significant time or affects your performance at ARETION;

– Creates a reputational risk to ARETION;

– Involves advice or services similar to what ARETION provides.

5.7 Failure to Disclose

Failure to disclose a known or suspected conflict of interest is a serious breach of this Code and will result in disciplinary action, which may include dismissal.

5.8 Seeking Guidance

If you are unsure whether something is a conflict of interest:

– Ask your manager;

– Contact the Compliance and Ethics team: compliance@aretion.co.uk;

– Err on the side of disclosure (it is better to disclose and be told no action is needed than to conceal a conflict).

We will not penalise you for disclosing a conflict in good faith.

6. CONFIDENTIALITY, DATA PROTECTION, AND INFORMATION SECURITY

6.1 Why This Matters

ARETION & Company handles sensitive and confidential information:

– Patient data and health records;

– Client strategic and commercial information;

– Financial and operational data;

– Proprietary research and analysis;

– Employee personal information;

– Digital systems and security credentials.

We are committed to protecting this information. Breach of confidentiality, data protection, or information security could:

– Harm patients and individuals;

– Violate legal obligations (UK GDPR, Data Protection Act 2018);

– Result in regulatory enforcement action and fines;

– Damage client relationships and business;

– Undermine trust in our organisation;

– Expose individuals to identity theft or fraud.

Everyone is responsible for protecting confidential and personal information.

6.2 Patient Data and Health Records

Patient data is highly sensitive and is protected by data protection law. We handle patient data only:

– With appropriate lawful basis (typically consent, legal obligation, or legitimate interest);

– For defined, legitimate purposes;

– With proper security measures;

– For only as long as necessary.

We do not:

– Share patient data without consent unless legally required;

– Use patient data for purposes beyond those disclosed to the patient;

– Retain patient data longer than necessary;

– Sell or commercialise patient information;

– Share patient data with third parties without appropriate agreements.

If you have questions about patient data handling, contact the Compliance and Ethics team or our Data Protection Officer: dpo@aretion.co.uk

6.3 Client Confidential Information

Clients share strategic plans, financial information, operational data, and business strategies with us. This information is confidential and proprietary. We:

– Protect it from unauthorised access and disclosure;

– Use it only for the purpose for which it was shared;

– Do not disclose it to third parties without client permission;

– Return or securely destroy it when the engagement ends;

– Implement information barriers to prevent misuse between competing clients.

6.4 Information Security

We maintain information security measures to protect all information from:

– Unauthorised access;

– Theft or loss;

– Accidental or malicious damage;

– Cyber attack.

You must:

– Use strong passwords and multi-factor authentication;

– Not share your login credentials with anyone;

– Lock your computer when you leave your desk;

– Not access systems or data beyond what is necessary for your role;

– Report security incidents immediately;

– Follow guidance from our Information Security team;

– Not connect personal devices to ARETION systems without approval;

– Not download confidential information to personal devices without encryption and approval.

6.5 Data Protection and Privacy

ARETION & Company complies with UK GDPR and the Data Protection Act 2018. We have appointed a Data Protection Officer who oversees our compliance: dpo@aretion.co.uk

Your personal data rights:

– You have the right to access your personal data;

– You have the right to request correction of inaccurate data;

– You have the right to request deletion in certain circumstances;

– You have rights to restrict processing and object to certain uses;

– You have the right to data portability;

– You have the right not to be subject to automated decision-making.

To exercise these rights or to understand how your data is processed, contact our Data Protection Officer: dpo@aretion.co.uk

6.6 Social Media and Public Disclosure

You must not disclose confidential information on social media, in public forums, or in any public context without explicit permission. This includes:

– Patient information (even anonymised if identifiable);

– Client information;

– Internal discussions or debates;

– Unpublished research or analysis;

– Commercial strategies or relationships.

If you wish to publish or publicly discuss work you have done for ARETION, obtain permission from your manager and the Compliance team.

6.7 Whistleblowing and Public Interest Disclosure

While we prioritise confidentiality, we recognise that sometimes confidentiality must yield to public interest—particularly where there is evidence of illegal conduct, breaches of professional ethics, or serious harm to patients or the public.

If you have evidence of serious wrongdoing, you can report it through our Whistleblowing Procedure (see Section 16) even if it involves disclosure of confidential information. Public interest disclosures are protected by law, and we will not retaliate against you for making such a disclosure in good faith.

7. PROFESSIONAL CONDUCT WITH CLIENTS AND PROTECTION OF PATIENTS’ INTERESTS

7.1 Our Professional Duty

ARETION & Company and its subsidiaries exist to improve healthcare. Healthcare is a matter of life and death. Our professional conduct and the advice we give have real consequences for patients and communities.

We are committed to:

– Providing honest, competent, evidence-based advice;

– Prioritising patient safety and wellbeing;

– Being transparent about the limits of our expertise;

– Challenging advice or decisions that could harm patients;

– Respecting patient autonomy and informed consent;

– Operating with integrity even when it costs us business.

7.2 Competence and Scope of Practice

We only undertake work we are competent to deliver. We:

– Clearly describe our qualifications and experience;

– Do not accept work beyond our expertise without appropriate support or training;

– Acknowledge the limits of our knowledge and experience;

– Refer clients to other specialists when appropriate;

– Invest in continuous professional development;

– Maintain professional registration and credentials where required.

We do not:

– Overstate our experience or capabilities;

– Accept work we cannot complete competently;

– Present ourselves as having expertise we do not possess;

– Claim credentials we do not hold.

7.3 Honest and Objective Advice

Our value to clients lies in our objectivity and independence. We provide advice based on evidence and professional judgment, not on what clients want to hear or what is commercially convenient.

We:

– Conduct rigorous analysis and research;

– Base recommendations on evidence and methodology;

– Challenge client assumptions when evidence contradicts them;

– Explain the reasoning behind our recommendations;

– Disclose material limitations or uncertainties;

– Do not allow conflicts of interest or financial incentives to bias our advice.

We do not:

– Tell clients what they want to hear;

– Adjust findings to match client preferences;

– Conceal contrary evidence;

– Allow financial arrangements to compromise objectivity;

– Recommend solutions that are not in client or patient interests.

7.4 Patient Safety and Wellbeing

In all healthcare advice and recommendations, patient safety and wellbeing are paramount. We:

– Evaluate recommendations against patient safety criteria;

– Do not recommend changes that could harm patients without clear clinical justification;

– Challenge proposals that would compromise patient access to care, equity, or dignity;

– Consider the needs of vulnerable populations;

– Raise concerns if we believe a client’s proposal could harm patients;

– Document our reasoning and concerns.

We will not recommend actions we believe could harm patients, regardless of client pressure or financial incentive.

7.5 Informed Consent and Transparency

We work transparently with clients. We:

– Clearly explain what we will do and what deliverables will be provided;

– Disclose conflicts of interest;

– Explain our methodology and limitations;

– Obtain written consent before using client information in publications or case studies;

– Explain fees and costs upfront;

– Report progress and any issues that arise.

We do not:

– Conceal fees or unexpected costs;

– Use client information in publications without permission;

– Mislead clients about what will be delivered;

– Hide methodological limitations or conflicts.

7.6 Handling Client Disputes and Complaints

If a client has a concern or complaint about our work:

– We will take it seriously;

– We will respond promptly and transparently;

– We will investigate the concern fairly;

– We will take appropriate action to address legitimate concerns;

– We will not retaliate against clients who raise concerns.

Clients who wish to make a complaint can contact: complaints@aretion.co.uk

8. FAIR TREATMENT, DIVERSITY, EQUITY, INCLUSION, AND ANTI-HARASSMENT

8.1 Our Commitment

ARETION & Company is committed to creating a workplace and providing services that are fair, respectful, inclusive, and free from discrimination and harassment. We value diversity and believe that diverse teams deliver better outcomes.

We are committed to:

– Equal opportunity in recruitment, promotion, and career development;

– Fair pay and reward;

– Respectful treatment of all people regardless of background;

– Creating an environment where everyone can thrive;

– Addressing discrimination, harassment, and bullying;

– Supporting flexible working and work-life balance;

– Reasonable adjustments for people with disabilities.

8.2 Equality and Non-Discrimination

We comply with the Equality Act 2010 and do not discriminate on the basis of:

– Age;

– Disability;

– Gender reassignment;

– Marriage or civil partnership status;

– Pregnancy or maternity;

– Race or ethnicity;

– Religion or belief;

– Sex or gender;

– Sexual orientation;

– Trade union membership.

Discrimination includes:

– Direct discrimination (treating someone less favourably because of a protected characteristic);

– Indirect discrimination (applying a provision, criterion, or practice that disadvantages people with a protected characteristic);

– Harassment (unwanted conduct that violates dignity or creates an intimidating, hostile, offensive environment);

– Victimisation (treating someone unfairly because they have made a complaint or supported someone else’s complaint);

– Failure to make reasonable adjustments for people with disabilities.

We do not tolerate discrimination or harassment in any form.

8.3 Harassment and Bullying

Harassment is unwanted conduct related to a protected characteristic that violates dignity or creates an intimidating, hostile, offensive, or degrading environment. Bullying is persistent, offensive, abusive, intimidating, or insulting behaviour.

We do not tolerate:

– Sexual harassment or unwanted sexual conduct;

– Harassment based on race, ethnicity, religion, disability, or any protected characteristic;

– Bullying or aggressive behaviour;

– Intimidation or threats;

– Exclusion or isolation;

– Spreading rumours or gossip;

– Unwanted physical contact.

If you experience or witness harassment or bullying, report it immediately.

8.4 Inclusive Workplace

We strive to create an inclusive workplace where everyone feels valued and can contribute. We:

– Use inclusive language that respects gender identity, disability, and cultural differences;

– Provide reasonable adjustments for people with disabilities;

– Offer flexible working arrangements where possible;

– Support career development for all employees;

– Ensure decision-making processes are fair and transparent;

– Listen to employee feedback and act on concerns;

– Celebrate diversity in our team and client base.

8.5 Diversity and Health Equity

Healthcare is not equally accessible or outcomes equally good for all populations. We recognise health inequalities based on ethnicity, socioeconomic status, geography, disability, and other factors. We are committed to:

– Understanding and addressing health inequalities in our work;

– Considering equity implications of our advice and recommendations;

– Ensuring our teams have diverse perspectives to identify blind spots;

– Working with communities affected by health inequalities;

– Advocating for equitable healthcare access and outcomes;

– Monitoring and reporting on diversity within our organisation.

8.6 Reporting Discrimination or Harassment

If you experience or witness discrimination or harassment:

– Report it to your manager or HR department;

– Use our Whistleblowing Procedure (see Section 16) if you are uncomfortable reporting to your manager;

– Contact our external Whistleblowing Hotline;

– Document what happened (dates, names, witnesses, communications).

We will investigate all reports confidentially and will not tolerate retaliation against anyone who reports concerns in good faith.

9. HUMAN RIGHTS, MODERN SLAVERY, AND RESPONSIBLE SUPPLY CHAIN

9.1 Our Commitment

ARETION & Company respects human rights and is committed to operating ethically and responsibly throughout our supply chain. We comply with the Modern Slavery Act 2015 and all applicable human rights laws.

We are committed to:

– Ensuring our operations respect human rights;

– Preventing forced labour, child labour, and exploitation;

– Ensuring fair wages and working conditions;

– Respecting freedom of association and collective bargaining;

– Responsibly sourcing goods and services;

– Working with suppliers who share our values.

9.2 Modern Slavery

Modern slavery includes:

– Forced labour (work performed under threat, coercion, or debt bondage);

– Human trafficking (movement of people for exploitation);

– Child labour (employing children below legal minimum age or in dangerous work);

– Servitude (being held in a state of servitude or forced service);

– Debt bondage (obligation to work to pay off a debt);

– Exploitation of migrant workers.

ARETION & Company has a zero-tolerance policy on modern slavery. We do not:

– Employ or contract with anyone involved in forced labour, trafficking, or child labour;

– Knowingly work with suppliers who engage in these practices;

– Use recruitment practices that are exploitative or involve deception;

– Withhold wages or documents to control workers.

9.3 Our Supply Chain

We work with suppliers for services including:

– IT and technology services;

– Facilities and office management;

– Professional services and consultancy;

– Publications and printing;

– Recruitment and staffing;

– Travel and logistics.

We ensure that:

– Suppliers are vetted for human rights and labour practice concerns;

– Modern slavery clauses are included in all supplier contracts;

– Suppliers are required to comply with applicable labour laws;

– We conduct due diligence on higher-risk suppliers;

– We investigate and take action if we become aware of concerning practices.

9.4 Working Conditions and Fair Wages

We are committed to fair working conditions across our supply chain:

– Fair wages that meet or exceed local legal minimums;

– Safe and healthy working conditions;

– Reasonable working hours and rest periods;

– Freedom from harassment and discrimination;

– Right to join unions or worker organisations;

– No requirement to work in dangerous conditions without proper protection.

9.5 Reporting Concerns

If you suspect modern slavery, exploitation, or unfair labour practices in our supply chain or operations:

– Report to your manager or HR;

– Contact the Compliance and Ethics team: compliance@aretion.co.uk;

– Use our Whistleblowing Procedure (see Section 16);

– Contact our external Whistleblowing Hotline.

We will investigate all reports confidentially and will not tolerate retaliation.

9.6 Transparency and Accountability

We report annually on our modern slavery and human rights compliance. Our Modern Slavery Statement is available publicly and describes:

– Our operations and supply chain;

– Risks we have identified;

– Steps we have taken to address risks;

– Effectiveness of our measures;

– Future commitments.

10. HEALTH, SAFETY, AND WELLBEING AT WORK

10.1 Our Commitment

ARETION & Company is committed to providing a safe, healthy, and supportive workplace. We comply with the Health and Safety at Work etc. Act 1974 and all relevant health and safety regulations.

We are committed to:

– Identifying and controlling workplace hazards;

– Preventing accidents and work-related ill health;

– Providing safe equipment, systems, and processes;

– Supporting mental health and wellbeing;

– Creating a culture where safety is everyone’s responsibility;

– Involving employees in health and safety decisions.

10.2 Individual Responsibilities

Every employee is responsible for health and safety:

– Take care of your own health and safety;

– Take care not to harm others;

– Report hazards, incidents, and near-misses immediately;

– Use safety equipment and follow procedures;

– Participate in training and risk assessments;

– Raise concerns if you believe something is unsafe;

– Do not work under the influence of drugs or alcohol;

– Report injuries and illnesses promptly.

10.3 Workplace Hazards

We identify and control hazards including:

– Physical hazards (equipment, facilities, manual handling);

– Chemical hazards (cleaning materials, office chemicals);

– Biological hazards (bloodborne pathogens where relevant);

– Psychological hazards (stress, bullying, overwork);

– Ergonomic hazards (poor workstation setup, repetitive strain);

– Infection control (particularly relevant post-COVID).

10.4 Mental Health and Wellbeing

We recognise that mental health is as important as physical health. We are committed to:

– Recognising signs of stress, anxiety, depression, and burnout;

– Supporting employees experiencing mental health challenges;

– Creating a culture where mental health can be discussed openly;

– Providing access to counselling and mental health support;

– Managing workload to prevent excessive stress;

– Supporting flexible working and time off when needed;

– Training managers to recognise and respond to mental health concerns.

If you are struggling with mental health, please reach out to:

– Your manager;

– HR department;

– Employee Assistance Programme (details provided upon joining);

– External support services (your GP, NHS services, charities).

10.5 Substance Abuse

ARETION & Company is committed to supporting employees with substance abuse issues while maintaining a safe workplace.

We:

– Do not tolerate working under the influence of drugs or alcohol;

– Offer confidential support and treatment for employees with substance abuse problems;

– Will not penalise employees who come forward seeking help;

– May take disciplinary action if substance abuse affects work performance or safety;

– Comply with drug and alcohol testing policies where required.

If you or a colleague are struggling with substance abuse, contact HR or the Employee Assistance Programme for confidential support.

10.6 Incident Reporting

All accidents, injuries, near-misses, and health and safety concerns must be reported immediately:

– Report to your manager;

– Report to the Health and Safety team;

– Seek medical attention if injured;

– Complete an incident report form;

– Cooperate with any investigation.

Do not be afraid to report near-misses or concerns—reporting helps us prevent future incidents.

10.7 Remote and Flexible Working

ARETION & Company supports flexible working where possible. Employees working remotely or flexibly are responsible for:

– Setting up a safe workstation (desk, chair, lighting);

– Taking regular breaks and managing workload;

– Maintaining security of company information and devices;

– Following video call etiquette and respecting others’ time;

– Staying connected with the team.

Managers are responsible for supporting remote workers and monitoring wellbeing.

11. USE OF COMPANY ASSETS, TECHNOLOGY, INTELLECTUAL PROPERTY, AND ACCEPTABLE USE

11.1 Company Assets

ARETION & Company provides employees with assets including:

– Computers, laptops, tablets, and mobile devices;

– Software licenses and digital tools;

– Office space and facilities;

– Research databases and information resources;

– Company vehicles (where applicable);

– Professional development budgets.

You must:

– Use company assets only for work purposes (or personal use as explicitly permitted);

– Look after equipment and report damage or loss;

– Return all assets when you leave employment;

– Not remove company property without permission;

– Not lend company equipment to others without approval.

11.2 Technology and Devices

Company-provided devices (computers, phones, tablets) are company property. We may:

– Monitor device security and compliance;

– Track location of devices (for security purposes);

– Access company files and communications on devices;

– Monitor internet use and email for compliance and security;

– Wipe devices remotely if lost or stolen.

You should have no expectation of privacy in company devices or accounts. If you have personal matters you want to keep private, use your personal devices and personal email.

You must:

– Use strong passwords and multi-factor authentication;

– Lock devices when you leave your desk;

– Not share login credentials;

– Not download unauthorised software;

– Not bypass security measures;

– Report lost or stolen devices immediately;

– Follow guidance from the IT and Information Security teams.

11.3 Email and Communications

Company email accounts and communication systems are for work purposes. We:

– Monitor email and messages for security, compliance, and legal reasons;

– Retain records of business communications;

– May access your email if you are unavailable or upon investigation of misconduct;

– Do not tolerate use of company email for harassment, discrimination, or illegal activity.

You should have no expectation of privacy in your work email account.

You must not:

– Send abusive, harassing, or discriminatory messages;

– Send defamatory or false information;

– Share confidential information inappropriately;

– Use email for personal business beyond reasonable use;

– Forward company information to personal email accounts without approval.

11.4 Internet Use

Company internet and networks are for work purposes. Incidental personal use (checking personal email, reading news) is permitted during breaks, provided it:

– Does not interfere with work;

– Is not excessive;

– Does not access illegal or inappropriate content.

We monitor internet use for security, compliance, and legal purposes. You should have no expectation of privacy.

You must not access:

– Pornographic or sexually explicit material;

– Illegal content;

– Gambling websites;

– Extremist or hate speech content;

– Sites that could compromise security or introduce malware.

11.5 Social Media

You are free to maintain personal social media accounts and to express personal views on social media. However:

– Do not disclose confidential company or client information;

– Do not represent yourself as speaking for ARETION unless authorised;

– Be aware that your posts could affect ARETION’s reputation;

– Do not engage in harassment, discrimination, or abusive behaviour;

– Follow applicable laws regarding data protection, defamation, and harassment.

If you are authorised to represent ARETION on social media, you must:

– Follow our social media guidelines;

– Disclose that you are speaking on behalf of ARETION;

– Comply with this Code and all applicable laws;

– Report concerns or complaints to your manager.

11.6 Intellectual Property

Work created for ARETION belongs to ARETION. This includes:

– Documents, reports, analysis, and recommendations created for clients;

– Research, data analysis, and methodology developed during employment;

– Software, code, and digital tools created for ARETION;

– Publications, articles, and educational materials created in your role;

– Inventions and patents developed using ARETION resources.

When you join ARETION, you will sign an intellectual property agreement confirming this.

Your personal intellectual property remains yours. Work created on your own time, with your own resources, and not related to ARETION’s business belongs to you.

11.7 External Publications and Speaking Engagements

If you wish to publish work or speak publicly about work you have done for ARETION:

– Obtain written permission from your manager;

– Obtain written permission from the Compliance team if the work involves client information;

– Do not disclose confidential information or client names without permission;

– Clearly attribute ideas and contributions;

– Disclose any conflicts of interest (e.g. financial interest in a product you are discussing).

We support publication and speaking to advance knowledge, but these must be done transparently and with proper permissions.

11.8 Personal Use of Company Resources

Limited personal use of company resources is permitted:

– Using office facilities for genuine emergencies;

– Making occasional personal phone calls;

– Sending occasional personal emails during breaks;

– Using the internet for reasonable personal purposes during breaks.

Excessive personal use is not permitted and may result in disciplinary action.

12. INSIDER INFORMATION, MARKET ABUSE, AND HANDLING SENSITIVE COMMERCIAL INFORMATION

12.1 Insider Information

Insider information is non-public information that, if disclosed to the public, would likely affect the price or value of securities (shares or bonds) of a company. If you have access to insider information about any listed company:

– Do not trade in that company’s securities;

– Do not disclose the information to others;

– Do not encourage others to trade on the basis of the information;

– Report any concerns to the Compliance team.

This applies even if ARETION is not the subject of the insider information.

12.2 Market Abuse

Market abuse includes:

– Insider trading (trading on the basis of inside information);

– Market manipulation (spreading false information to manipulate prices);

– Misuse of confidential information for personal gain.

Market abuse is illegal and can result in criminal prosecution, civil penalties, and imprisonment.

We do not tolerate market abuse.

12.3 Sensitive Commercial Information

ARETION and our clients hold sensitive commercial information including:

– Business plans and strategies;

– Financial data and performance;

– Pricing and cost information;

– Client lists and relationships;

– Technology platforms and methodologies;

– Tender bids and proposals;

– Merger and acquisition activity.

You must:

– Treat this information as confidential;

– Restrict access to those who need to know;

– Not disclose it to competitors or external parties without permission;

– Not use it for personal gain;

– Return or destroy it when you leave employment;

– Report unauthorised access or disclosure.

12.4 Tender and Procurement Process

When ARETION bids for work:

– All bids must be genuine and accurate;

– Do not disclose confidential pricing information to competitors;

– Do not share tender details with clients in ways that could disadvantage them or advantage competitors;

– Do not engage in bid-rigging or collusion;

– Follow all procurement process rules and timelines.

Breaches of tender integrity are serious and may result in disqualification from future contracts and legal liability.

13. RESEARCH ETHICS, DATA ANALYTICS, AND AI/ALGORITHMIC FAIRNESS

13.1 Research Ethics

ARETION & Company respects research ethics principles. All research involving human participants, patient data, or sensitive information must:

– Obtain ethical approval from a recognised ethics committee (where required);

– Obtain informed consent from participants (where required);

– Respect participant autonomy and right to withdraw;

– Minimise harm and maximise benefit;

– Respect confidentiality and privacy;

– Be transparent about funding and conflicts of interest;

– Comply with relevant research regulations (e.g. Research Governance Framework, MRC Guidance);

– Be registered on a public trial register (for clinical trials).

Research must not:

– Exploit vulnerable populations;

– Involve deception (except where ethically justified and approved);

– Put participants at unreasonable risk;

– Violate privacy or confidentiality.

13.2 Data Analytics and Analysis

When we analyse data for clients or research:

– Analysis must be rigorous, transparent, and reproducible;

– Methodology must be clearly described;

– Limitations must be disclosed;

– We do not manipulate data or findings to reach predetermined conclusions;

– We disclose uncertainties and confidence intervals;

– We do not present preliminary findings as definitive;

– We do not conceal results that contradict our hypothesis or client preferences.

13.3 Artificial Intelligence and Algorithmic Fairness

ARETION & Company recognises that artificial intelligence (AI) and algorithmic systems can embed bias and cause harm. We are committed to responsible AI.

When developing or recommending AI systems, we:

– Assess fairness implications across different population groups;

– Test for bias in training data and algorithmic outputs;

– Do not recommend AI systems that discriminate against protected groups;

– Ensure systems are transparent and explainable (where possible);

– Consider privacy implications and data protection requirements;

– Obtain informed consent for use of personal data in AI systems;

– Monitor performance over time and adjust if bias emerges;

– Disclose limitations and uncertainties;

– Do not make irreversible decisions based solely on algorithmic recommendations without human review.

13.4 Data Minimisation and Purpose Limitation

When collecting or using data:

– Collect only data necessary for the stated purpose;

– Do not retain data longer than necessary;

– Do not use data for purposes beyond those disclosed to the data subject;

– Implement data protection by design;

– Minimise the collection of sensitive data (race, ethnicity, sexuality, health);

– Ensure technical and organisational security measures.

13.5 Transparency and Explainability

We are committed to transparency in our analysis and recommendations:

– Explain how we reached conclusions;

– Disclose methodological choices and limitations;

– Make data and code available for scrutiny (where possible and permitted);

– Disclose conflicts of interest that could affect analysis;

– Explain the limitations of what can be concluded from data.

14. ENVIRONMENTAL AND SOCIAL RESPONSIBILITY

14.1 Environmental Commitment

ARETION & Company is committed to minimising environmental impact and supporting the transition to a sustainable economy. Healthcare systems must operate sustainably to serve future generations.

We are committed to:

– Reducing carbon emissions from our operations;

– Minimising waste and promoting recycling;

– Using sustainable procurement practices;

– Supporting clients in building environmentally sustainable health systems;

– Complying with environmental laws and regulations;

– Measuring and reporting on environmental performance;

– Investing in renewable energy and low-carbon technologies.

14.2 Carbon and Emissions

– Switching off equipment when not in use;

– Printing only when necessary and double-sided;

– Recycling paper, plastics, and other materials;

– Using reusable cups and containers;

– Reporting energy waste or equipment problems.

14.3 Sustainable Procurement

When ARETION & Company procures goods and services, we:

– Consider environmental impact (carbon footprint, waste, resource use);

– Prefer suppliers with strong environmental credentials;

– Source materials sustainably (e.g. recycled, certified sustainable);

– Minimise packaging and single-use plastics;

– Support local suppliers where possible to reduce transport emissions;

– Include environmental clauses in supplier contracts;

– Monitor supplier compliance with environmental standards.

14.4 Sustainable Healthcare

Healthcare systems consume significant resources and generate emissions. We support clients in:

– Reducing carbon emissions from healthcare facilities;

– Minimising waste and promoting circular economy principles;

– Optimising energy and resource use;

– Reducing unnecessary procedures and medication;

– Building resilience to climate change impacts;

– Addressing health inequalities related to environmental degradation;

– Supporting sustainable workforce planning and development.

14.5 Social Responsibility

ARETION & Company operates responsibly within society. We:

– Comply with all applicable laws and regulations;

– Pay fair taxes in all jurisdictions where we operate;

– Contribute to communities where we work;

– Support charitable and community initiatives;

– Promote public health and wellbeing;

– Advocate for evidence-based healthcare policy;

– Challenge health inequalities and injustice;

– Support local employment and skills development.

14.6 Community Engagement

We engage with communities affected by our work and recommendations. We:

– Listen to community perspectives and concerns;

– Involve communities in decisions that affect them;

– Make information accessible and transparent;

– Support community health initiatives;

– Work with community organisations and representatives;

– Consider impact on vulnerable and disadvantaged groups;

– Report back on outcomes of our work.

14.7 Charitable Giving and Sponsorship

ARETION & Company supports charitable causes aligned with our values. Our charitable giving:

– Supports health improvement, healthcare access, and health equity;

– Supports medical research and education;

– Supports vulnerable populations and communities;

– Is transparent and publicly reported;

– Does not create conflicts of interest or influence our professional judgment.

Employees are encouraged to volunteer and support charitable causes on their own time.

15. RECORD-KEEPING, DOCUMENTATION, AND REPORTING ACCURACY

15.1 Accurate Records

ARETION & Company relies on accurate records for:

– Legal compliance and regulatory reporting;

– Client billing and financial management;

– Financial reporting and audit;

– Project management and delivery;

– Incident reporting and investigation;

– Personnel and employment records.

You must ensure that:

– All records you create or maintain are accurate and complete;

– Records are created promptly (not retrospectively);

– Records are legible and well-organised;

– Any errors are corrected promptly with clear audit trails;

– Records are retained according to our retention policy;

– Confidential records are securely stored and accessed;

– Records are not falsified, altered, or destroyed inappropriately.

15.2 Financial Records and Reporting

All financial records must be accurate and comply with accounting standards. This includes:

– Timesheets and expense claims;

– Invoicing and billing records;

– Project costs and budgets;

– Financial statements and reports;

– Tax records and compliance.

You must:

– Record time accurately on timesheets;

– Submit only legitimate business expenses;

– Provide receipts and documentation;

– Declare any conflicts of interest affecting financial decisions;

– Report financial irregularities or concerns.

15.3 Client Delivery and Project Records

Records of client work must:

– Accurately document what was agreed and what was delivered;

– Record decisions, recommendations, and reasoning;

– Maintain audit trails of changes and approvals;

– Document communications with clients;

– Record any issues, delays, or deviations from scope;

– Be organised and accessible.

Poor record-keeping can result in:

– Disputes with clients;

– Inability to demonstrate work was done correctly;

– Regulatory or legal problems;

– Disciplinary action.

15.4 Medical and Health Records

Where ARETION & Company handles medical or health records:

– Records must be accurate and timely;

– Records must be clearly documented and legible;

– Patient information must be clearly identifiable;

– Any corrections must be clearly marked;

– Confidentiality and security must be maintained;

– Records must be retained according to legal requirements (typically 10 years for adult records, longer for children).

15.5 Incident and Complaint Records

All incidents, complaints, and concerns must be documented:

– Record what happened, when, where, and who was involved;

– Record what actions were taken;

– Record outcomes and follow-up;

– Keep records confidential and secure;

– Do not alter or destroy records.

Good documentation of incidents protects both ARETION and individuals if disputes arise later.

15.6 Data Retention and Destruction

ARETION & Company has a data retention and destruction policy. We:

– Retain records only as long as necessary;

– Securely destroy records when no longer needed;

– Comply with legal retention requirements;

– Do not destroy records if involved in legal proceedings or investigation;

– Use secure methods of destruction (shredding, secure digital erasure).

Do not destroy records without authorisation or if you suspect they may be needed for legal or investigation purposes.

15.7 Record Access and Audit

ARETION & Company may:

– Audit records to ensure accuracy and compliance;

– Access records as part of investigations;

– Release records to regulators or law enforcement (with appropriate authority);

– Request records for quality assurance or improvement purposes.

Employees must cooperate with requests for records and audits.

16. SPEAKING UP, WHISTLEBLOWING, AND NON-RETALIATION

16.1 Our Commitment to Whistleblowing

ARETION & Company is committed to maintaining the highest ethical standards. We encourage and support employees, contractors, and partners to speak up about concerns without fear of retaliation.

We welcome concerns about:

– Illegal conduct (fraud, bribery, tax evasion, etc.);

– Breaches of this Code of Conduct;

– Breaches of professional ethics or standards;

– Health and safety risks or violations;

– Environmental violations;

– Discrimination, harassment, or bullying;

– Modern slavery or exploitation;

– Misuse of company assets or fraud;

– Data protection or privacy violations;

– Conflict of interest violations;

– Falsification of records or reporting;

– Any other conduct that violates law or ethics.

Speaking up is not disloyalty—it is essential to our integrity.

16.2 How to Raise a Concern

Internal channels (recommended first step):

1. Your manager: If you are comfortable doing so, raise the concern with your direct manager. They will listen and take appropriate action.

2. HR department: Contact HR if you prefer not to speak to your manager or if your manager is involved in the concern.

3. Compliance and Ethics team: Email compliance@aretion.co.uk with details of your concern. This team investigates concerns confidentially.

4. Senior leadership: Contact the Chief Executive or Chief Operating Officer if the concern involves senior management.

External channels:

5. External Whistleblowing Hotline: ARETION & Company has contracted with an independent external whistleblowing service. You can report concerns anonymously:

   – Telephone: +44 20 3985 0907

The external hotline is staffed by independent professionals, not ARETION employees. Reports are confidential and can be anonymous.

6. Public Interest Disclosure: In some cases, you may disclose concerns to external bodies:

   – Regulator: For healthcare, regulation, or patient safety concerns, contact the relevant regulator (e.g. NHS England, Care Quality Commission, Professional regulators).

   – Law enforcement: For concerns about criminal conduct, contact the police or relevant authority.

   – Legal advice: You may seek legal advice about whistleblowing protections.

16.3 What Information to Provide

When raising a concern, provide:

– Clear description of what you are concerned about;

– When and where it occurred (or is occurring);

– Who was involved (if known);

– Why you believe it is a concern (what law, policy, or ethic it breaches);

– Any evidence or documentation;

– Names of potential witnesses (if applicable).

You do not need to have definitive proof—a reasonable concern is sufficient.

16.4 Confidentiality and Anonymity

– We will treat your concern confidentially;

– We will not disclose your identity without your permission (except where required by law or for investigation purposes);

– You may report anonymously if you wish, though it may limit our ability to ask clarifying questions;

– Investigation findings will be shared with you (unless you report anonymously);

– Your cooperation in an investigation will be handled sensitively and confidentially.

16.5 Protection Against Retaliation

ARETION & Company prohibits retaliation against anyone who raises a concern in good faith.

Retaliation includes:

– Dismissal or disciplinary action;

– Demotion or loss of promotion;

– Harassment or bullying;

– Exclusion from meetings or information;

– Negative performance reviews;

– Removal from projects;

– Any adverse action taken because of the concern.

If you experience retaliation after reporting a concern, report it immediately as a separate concern.

We will investigate retaliation allegations seriously and take action against anyone who retaliates.

16.6 Legal Protections

Depending on the nature of your concern and how you report it, you may have legal protections under:

– Public Interest Disclosure Act 1998: Protects workers who disclose information about legal breaches, health and safety risks, or other serious concerns. You must have reasonable belief the concern is true, be acting in the public interest, and follow reasonable procedures.

– Professional regulators: Healthcare professionals can report concerns to their professional bodies (GMC, NMC, etc.) with legal protections.

– Specific legislation: Other sectors have specific whistleblowing protections (financial services, tax, etc.).

Seek independent legal advice if you are unsure about your protections.

16.7 Investigation Process

When you raise a concern, ARETION & Company will:

1. Acknowledge receipt: We will acknowledge your concern promptly (within 5 working days).

2. Assess the concern: We will determine if the concern requires investigation and what action is appropriate.

3. Investigate: We will conduct a fair, impartial investigation. This may involve:

   – Interviewing relevant people;

   – Reviewing documents and evidence;

   – Consulting with specialists or external parties;

   – Taking interim measures to protect people or assets if necessary.

4. Report findings: We will report findings to relevant people (the person about whom the concern was raised, relevant managers, HR, etc.) and to you (unless you requested anonymity).

5. Take action: If the concern is substantiated, we will take appropriate action:

   – Disciplinary action against individuals;

   – Changes to policies or procedures;

   – Referral to external authorities (regulators, police);

   – Remedial measures to address the harm.

6. Follow-up: We will follow up to ensure the concern has been properly addressed and there is no retaliation.

Investigations are confidential, but we may need to disclose information to those directly involved or to external authorities.

16.8 Vexatious or False Reports

While we welcome genuine concerns, false or vexatious reports (made maliciously or without reasonable belief) may result in disciplinary action.

However, we do not penalise good-faith reports even if they are ultimately found to be incorrect.

17. RESPONSIBILITIES OF MANAGERS AND LEADERS

17.1 Leadership Accountability

Managers and leaders at ARETION & Company are responsible for:

– Upholding and modeling the values in this Code;

– Creating a culture of ethical conduct;

– Ensuring their teams understand and comply with this Code;

– Identifying and managing conflicts of interest;

– Monitoring work quality and ethical standards;

– Supporting employee wellbeing and mental health;

– Responding to concerns and complaints fairly and promptly;

– Taking action against misconduct;

– Protecting whistleblowers from retaliation;

– Being transparent and accountable;

– Promoting diversity, inclusion, and fair treatment.

17.2 Setting the Tone

Leaders set the tone for ethical conduct. We expect leaders to:

– Demonstrate integrity in their own conduct;

– Make ethical decisions even when costly or difficult;

– Challenge unethical conduct by colleagues or clients;

– Be transparent about conflicts of interest;

– Listen to and act on employee concerns;

– Support people who raise concerns;

– Communicate the importance of compliance and ethics;

– Celebrate ethical conduct and good decision-making.

17.3 Managing Conflicts of Interest

Managers must:

– Ask team members about potential conflicts of interest;

– Disclose their own conflicts of interest;

– Implement appropriate management strategies for conflicts;

– Review conflicts regularly and adjust management as needed;

– Ensure conflicted individuals are not involved in inappropriate decisions;

– Document conflict of interest management.

17.4 Promoting Wellbeing

Managers are responsible for supporting the wellbeing of their teams:

– Monitor workload and stress levels;

– Encourage work-life balance and time off;

– Support flexible working where possible;

– Be alert to signs of mental health difficulties;

– Create a supportive environment where people feel safe raising concerns;

– Know how to signpost people to support services;

– Take action to address bullying or harassment;

– Promote diversity and inclusion.

17.5 Quality and Professional Standards

Managers must ensure that:

– Work is of high quality and completed competently;

– Staff are appropriately trained and developed;

– Professional standards are met;

– Client requirements are clearly understood and met;

– Issues and risks are identified and escalated appropriately;

– Records are accurate and complete;

– Ethical standards are maintained.

17.6 Responding to Concerns and Complaints

When a team member raises a concern or complaint, managers must:

– Take it seriously and listen respectfully;

– Not dismiss or minimise the concern;

– Explain what will happen next;

– Maintain confidentiality;

– Not retaliate or allow retaliation;

– Investigate fairly and promptly;

– Report findings and actions taken;

– Follow up to ensure the concern is resolved.

17.7 Disciplinary Responsibility

Managers are responsible for addressing misconduct by team members:

– Take prompt action if misconduct is suspected;

– Investigate fairly;

– Follow ARETION’s disciplinary procedures;

– Ensure proportionate action based on the seriousness of the misconduct;

– Document decisions and reasoning;

– Comply with employment law.

Failure to address known misconduct is itself a serious breach of responsibility.

18. MONITORING, ACCOUNTABILITY, AND CONSEQUENCES OF BREACHES

18.1 Monitoring and Compliance

ARETION & Company monitors compliance with this Code through:

– Regular audits and reviews;

– Training and awareness programs;

– Incident reporting and investigation;

– Anonymous surveys and feedback;

– Whistleblowing hotline;

– Performance management and appraisals;

– Audit trails and record review;

– Risk assessments;

– Regulatory inspections and audits.

All employees and contractors are subject to monitoring to ensure compliance.

18.2 Training and Awareness

We ensure all employees understand their obligations:

– New employees receive Code of Conduct training within their first month;

– All employees receive annual refresher training;

– Specific training is provided on high-risk areas (anti-bribery, data protection, conflicts of interest);

– Managers receive additional training on their compliance responsibilities;

– Specialist teams receive targeted training (healthcare professionals, researchers, etc.);

– Induction materials include this Code.

Completion of training is mandatory.

18.3 Consequences of Breaches

Breaches of this Code are taken seriously. Consequences depend on the nature, severity, and intent of the breach but may include:

Minor breaches:

– Verbal warning or counseling;

– Written warning;

– Training or education;

– Temporary suspension of privileges;

– Requirement to remediate or correct the breach.

Serious breaches:

– Formal written warning;

– Disciplinary suspension (with or without pay);

– Demotion or reallocation to different work;

– Requirement to divest financial interests or resign external positions;

– Dismissal without notice (in cases of gross misconduct);

– Referral to professional regulators;

– Referral to law enforcement;

– Civil liability or compensation claims.

18.4 Gross Misconduct

– Theft or fraud;

– Deliberate falsification of records or reports;

– Bribery or corruption;

– Serious breach of confidentiality or data protection;

– Gross negligence that causes serious harm;

– Serious misconduct involving violence, aggression, or threats;

– Sexual harassment or assault;

– Serious discrimination or bullying;

– Working under the influence of drugs or alcohol;

– Serious breach of health and safety;

– Deliberate concealment of a serious conflict of interest;

– Serious breach of professional ethics;

– Modern slavery or exploitation;

– Retaliation against a whistleblower;

– Serious dishonesty or deception;

– Any conduct that seriously breaches trust or brings ARETION into serious disrepute.

Gross misconduct may also result in referral to professional regulators, law enforcement, or other authorities.

18.5 Disciplinary Procedure

ARETION & Company follows fair disciplinary procedures:

1. Investigation: We investigate allegations promptly and thoroughly before taking action.

2. Notice: We provide written notice of the allegation and the evidence against you.

3. Right to respond: You have the right to respond to allegations and provide your account.

4. Right to representation: You have the right to be accompanied by a companion (colleague or union representative) at disciplinary meetings.

5. Impartiality: Disciplinary decisions are made by someone not involved in the investigation or incident.

6. Proportionality: Disciplinary action is proportionate to the seriousness of the breach.

7. Right to appeal: You have the right to appeal a disciplinary decision.

We follow employment law and best practice in all disciplinary matters.

18.6 Referral to External Authorities

ARETION & Company will refer matters to external authorities (regulators, law enforcement, professional bodies) where:

– A criminal offence is suspected;

– Regulatory breaches are identified;

– Professional standards are seriously breached;

– The public or patients are at risk;

– It is a legal requirement;

– We are required to do so by court order or authority.

We do not shield employees from legal consequences for misconduct.

18.7 Remediation and Recovery

Where a breach causes harm, ARETION & Company will:

– Take steps to remedy the harm;

– Compensate affected individuals where appropriate;

– Restore confidential information that has been breached;

– Implement measures to prevent recurrence;

– Review and improve policies and procedures;

– Provide support to affected individuals.

18.8 Accountability of Leadership

Senior leaders and managers are held to the highest standards of accountability. Breaches by leaders may result in:

– More serious disciplinary action than would apply to junior staff;

– Loss of position or responsibility;

– Requirement to step down from leadership role;

– Dismissal;

– Referral to professional regulators or law enforcement.

Leaders who fail to address known misconduct by their teams are themselves in breach of this Code.

19. CHANGES TO THIS CODE AND QUESTIONS

19.1 Regular Review

ARETION & Company reviews this Code regularly to ensure it remains current and relevant. We may update this Code:

– To reflect changes in law or regulation;

– To address emerging risks or ethical issues;

– To respond to feedback from employees and stakeholders;

– To reflect changes to ARETION’s business or values;

– To improve clarity and guidance.

All employees will be notified of significant changes, and new versions will be provided.

19.2 Questions and Guidance

If you have questions about this Code or are unsure how it applies to a specific situation:

– Ask your manager;

– Contact HR;

– Contact the Compliance and Ethics team: compliance@aretion.co.uk;

– Call the whistleblowing hotline for anonymous guidance.

We are happy to provide guidance and will not penalise you for asking questions in good faith.

19.3 Acknowledgment

All employees are required to:

– Read and understand this Code;

– Acknowledge receipt and agreement to comply;

– Complete training on the Code;

– Comply with the Code in their work and conduct.

Failure to comply with this Code is a breach of your employment contract and may result in disciplinary action.

This Code of Conduct sets out the ethical principles and standards expected of everyone who works for or represents ARETION & Company. It is not an exhaustive statement of all policies and procedures—other policies and procedures apply to specific areas. In case of conflict between this Code and other policies, the most specific policy applies. In case of ambiguity, seek clarification from the Compliance and Ethics team.

Last updated: 10 Feb 2026

Next review date: 10 Feb 2027