SCOPE
All International Group Facilities, including but not limited to, hospitals, Doctor practices and all
Corporate Departments. All Colleagues performing services for or on behalf of HCA entities.

PURPOSE
To establish acceptable parameters and limits for extending and receiving Business Courtesies.

DEFINITIONS
Business Associate is someone doing or seeking to do business with HCA or an HCA entity, including
a Doctor who has no contract with the NHS and who is not likely to be considered a UK Government
Employee or Foreign Public Official.
Business Courtesies are any item or service of value given to another free of cost. This includes
gifts and events sponsored or hosted by the Company that include some discussion of HCA’s
business. Examples of Business Courtesies include meals, sporting events, theatrical events,
receptions, or other entertainment or social events. Reasonable food and beverages served at
business meetings held for HCA purposes at an HCA Facility for which an agenda and minutes are
prepared are not considered Business Courtesies and are not subject to the Business Courtesy
provisions in the Code of Conduct or this policy. For avoidance of doubt, food and beverages
provided at meetings held at a restaurant should be treated as a Business Courtesy.
Colleague is a collective term for both Employees and Intermediaries.
Doctor includes: a general practitioner (GP), a doctor consultant, a doctor of medicine or
osteopathy, a doctor of dental surgery or dental medicine, a doctor of podiatric medicine, a doctor
of optometry, and a chiropractor.
Employee means members of staff employed by HCA International Limited whether in an HCA
International Facility or otherwise.
Facility means all HCA International hospitals and operations, whether medical or administrative or
otherwise, including, but not limited to, hospitals, diagnostic centres, private patient units, labs,
clinical trials and research units, Doctor practices and all HCA corporate departments, wherever
they may be located.
Foreign Public Official is any individual who (a) holds a legislative, administrative or judicial position
of any kind, whether appointed or elected, of a foreign country or territory outside the United
Kingdom (or any sub-division of such a country or territory); (b) exercises a public function (i) for or
on behalf of any country or territory outside the United Kingdom (or any sub-division of such a
country or territory) or (ii) for any public agency or public enterprise of that country or territory (or
sub-division); or (c) is an official or agent of a public international organisation.
Intermediary means an individual performing a service for or on behalf of HCA International Limited
including agents, representatives, joint venture partners, Doctors with consulting privileges, and
others. It does not include Employees. A party who is not performing services for or on behalf of
HCA International Limited will not constitute an Intermediary.
UK Government Employee is any person who (a) holds a legislative, administrative or judicial

position of any kind, whether appointed or elected, in the United Kingdom or (b) exercises a public
function (i) for or on behalf of the United Kingdom (or any sub-division thereof) or (ii) for any public
agency or public enterprise of the United Kingdom (or sub-division thereof). For the avoidance of
doubt, a Doctor who has a contract with the NHS is a UK Government Employee for purposes of the
Business Courtesy limits set forth in this Policy.

POLICY

Colleagues may provide Business Courtesies to third parties to establish cordial relations or to
promote HCA’s business. However, this policy prohibits Colleagues from providing or receiving
Business Courtesies that are intended to influence the recipient or any other person to do anything
improper or to inappropriately favour HCA or any other person.
Set out below is guidance for Colleagues on what is appropriate in different situations. Colleagues
must use their common sense at all times and must never offer a Business Courtesy as an incentive
to a third party to perform his/her duties improperly.

A: COLLEAGUES RECEIVING BUSINESS COURTESIES

1: Receiving Invitations to Attend Business Courtesy Events

HCA recognises that there will be times when a current or potential business associate may extend
an invitation to attend a social event to a Colleague in order to further develop a business
relationship. A Colleague is generally permitted to accept such an invitation subject to the
guidelines below, but the Colleague must never take into account any Business Courtesy received
when performing his or her duties for HCA. A Colleague must use common sense and judgment and
consider whether a Business Courtesy would create the impression of a conflict of interest. A
Colleague may accept an invitation only if:
the cost spent by the business associate and which is associated with such an event is
reasonable and appropriate, which, as a general rule, means the cost will not exceed £250
per person. If a Colleague suspects that the value of the Business Courtesy will exceed £250,
the Colleague must consult the Group Chief Finance Officer to get approval prior to
attending;

no reimbursement is given for any travel costs (other than in a vehicle owned privately or by
the host entity) or overnight lodging; and
such events are infrequent.

Reasonable food and beverages provided to Colleagues and served at business meetings held at an
office or medical facility for which an agenda and minutes are prepared are not considered Business
Courtesies and are not subject to the Business Courtesy provisions in the Code of Conduct or this
policy. Before accepting invitations to training or educational opportunities that include travel and
overnight accommodations at reduced or no cost to a colleague or HCA, Colleagues must follow the
procedures set out in the Vendor – Promotional Training, Business Associate-Sponsored Seminars
and Honoraria Policy (HCAUS.GOV.SM.POL.007).

2: Receiving Gifts

Colleagues must never accept a gift if it will influence, or appear to influence, the way they perform
their duties. Colleagues may accept gifts with a total value of £100 or less in any calendar year from
any individual or organisation which has an existing or prospective business relationship with HCA,
including physicians practicing in HCA Facilities, but may never accept cash, cash equivalents or
financial instruments (e.g., cheques or stocks), except that Employees may accept gift certificates.
Under no circumstances may a Colleague solicit a gift.
Perishable or consumable gifts given to a department or group (as opposed to an individual
Colleague) are not subject to any specific limitation but must always be reasonable and not
excessive.

B: HCA COLLEAGUES OFFERING BUSINESS COURTESIES

A Colleague must never offer a Business Courtesy with the intention of inducing or rewarding
improper conduct (including improperly referring patients to HCA Facilities). A Business Courtesy
can be offered only for a bona fide purpose such as to establish cordial relations or to legitimately
market HCA’s business. Business Courtesies must have a proper business justification, be
reasonable in the circumstances and not cause embarrassment if knowledge of the Business
Courtesy became public. Business Courtesies must never be in cash or a cash equivalent (such as
cheques, stock instruments, or gift certificates).

1: Applicable Limits

HCA places per instance and annual limits on the value of Business Courtesies that can be given to
third parties. The limit for a calendar-year period, to any one person (and his/her immediate
family) and in respect of the whole HCA group, is £500 (the “Annual Limit”). This means that the
aggregate value of every benefit provided by HCA Facilities to one person (and his/her immediate
family) must not exceed a combined total of £500 per year. The limit applies to all forms of
Business Courtesies offered, including events and gifts.
The chart below lists the per instance and annual limits generally applicable for different types of
Business Courtesies. However, different limits may apply for Business Courtesies offered to UK
Government Employees or Foreign Public Officials. Accordingly, please refer to Section B7 for
additional restrictions applicable to Business Courtesies given to UK Government Employees and to
the Global Anti-Corruption Policy, Appendix A (LL.AC.001) for Business Courtesies given to Foreign
Public Officials.

Colleagues should remember that simply because the value of a gift or event falls within the

applicable limits does not mean that it is appropriate. All Business Courtesies, even if within the
applicable limits, must be for a bona fide purpose. Nothing in this policy permits any Business
Courtesy or other benefit to be offered or provided with the intention of inducing or rewarding
referral of patients or business contrary to an individual’s proper duties, regulatory requirements or
professional ethics.
Expenditures in excess of the applicable limits must be authorised jointly in advance by the Group
Chief Finance Officer, the Executive Director/VP of Legal Services and the SVP and Chief Ethics and
Compliance Officer (or designee) (see section B9 below), who will assess compliance with the Global
Anti-Corruption Policy and Anti-Bribery Policy.
In the following limited instances, a Business Courtesy will not count towards a Doctor’s Annual
Limit:
a. A professional courtesy discount provided to a Doctor consistent with the Professional
Courtesy Discounts Policy (HCAUK.GOV.SM.POL.018) and any applicable Facility policy.
b. One Doctor appreciation event (including a seasonal or holiday party) per Facility per year so
long as (i) all Doctors who have practising privileges at the Facility are invited to attend; (ii)
the event is reasonable, proportionate and not lavish; and (iii) the cost per Doctor (and
his/her guest(s) is logged on the Business Courtesies Log by the Facility. However, any gifts
or gratuities provided in connection with the event are business courtesies and must be
tracked accordingly.
c. A Business Courtesy that (i) is offered to all Doctors within an entire Facility, within a certain
department of the Facility, or at an event such as a conference and (ii) is reasonable,
proportionate and not excessive (in no instance should the value be greater than £25). Such
Business Courtesies must be recorded in the Business Courtesies Log, unless they are HCA-

branded promotional items offered to the general public or to all Doctors at a large event
such as a conference. HCA-branded promotional items of a value generally less than £19 are
not required to be recorded in the Business Courtesies Log.

2: Giving Gifts

It is critical to avoid impropriety or the appearance of impropriety when giving gifts to individuals
who do business or are seeking to do business with HCA. Colleagues must never use gifts or other
incentives to improperly influence relationships or business outcomes or create a sense of
obligation. In order to avoid embarrassment, an effort should be made to ensure that any gift a
Colleague extends meets the business conduct standards of the recipient’s organisation. Gifts to
business associates who are not UK Government Employees must not exceed £150 per calendar
year, per recipient, and must count towards the Annual Limit. Please refer to Section B7 for
additional restrictions applicable to Business Courtesies given to UK Government Employees and to
the Global Anti-Corruption Policy, Appendix A (LL.AC.001), for Business Courtesies given to Foreign
Public Officials. An HCA colleague or Facility may never give cash, cash equivalents or financial
instruments (e.g., cheques, stocks, gift certificates).

3: Colleagues Hosting Business Courtesy Events

There may be times when a Colleague wishes to extend to a current or potential business associate
an invitation to attend a Business Courtesy event (e.g., reception, meal, sporting event, or theatrical
event) to further or develop a business relationship. The purpose of the Business Courtesy event
must never be to induce any improper business action or create any conflict of interest. During
these events, topics of a business nature must be discussed, and the HCA host must be present.
These Business Courtesy events must not include paying for any travel costs (other than in a vehicle
owned privately or by the host entity) or overnight lodging. The cost associated with such an event
must be reasonable and appropriate.
Such Business Courtesy events with respect to any particular individual must be infrequent, which,
as a general rule, means not more than three times per year. They may not be lavish or in
questionable taste.
For Business Courtesy events that are expected to exceed £250, Colleagues must submit in advance
a completed authorisation request form to the Group Chief Finance Officer, the Executive
Director/VP of Legal Services and the SVP and Chief Ethics and Compliance Officer (or designee). An
authorisation request must describe the business necessity and appropriateness of the proposed
Business Courtesy. The total amount spent on an individual (and his/her immediate family) must be
within the Annual Limit, unless authorized jointly by the Group Chief Finance Officer, the Executive
Director/VP of Legal Services and the SVP and Chief Ethics and Compliance Officer (or designee) in
advance. Colleagues are encouraged to stay within the £250 limit.
It is not permissible for the recipient of any Business Courtesy to pay part of its cost if the value
exceeds £250 with the intention to reduce the value to less than £250 and then accept the Business
Courtesy. Notwithstanding the limitation above, it is acceptable for the recipient of the Business
Courtesy to pay the full value of such courtesy and then participate in it.

4: Facilities Sponsoring Business Events

HCA Facilities may also sponsor events with a legitimate business purpose (e.g., hospital board
meetings or retreats). Provided that such events are for HCA’s business purposes, reasonable and
appropriate meals and entertainment may be offered. Prior written approval must be obtained
from both (i) the Group Chief Executive Officer or Group Chief Finance Officer and (ii) the Executive
Director/VP of Legal Services. In deciding whether such an event should be approved, the Group
Chief Executive Officer/Chief Finance Officer and the Executive Director/VP of Legal Services will
take into account the purpose of the event.
It is anticipated that HCA will not host events of a full day or more in duration (“longer event”) free
of charge. In the rare circumstance that HCA seeks to host a longer event for non-Employees, prior
approval must be obtained from both (i) the Group Chief Executive Officer or Group Chief Finance
Officer and (ii) the Executive Director/VP of Legal Services. In deciding whether such an event
should be approved, the Group Chief Executive Officer/Chief Finance Officer and the Executive
Director/VP of Legal Services will take into account the purpose of the event.
Sponsorship events should not be used as a reason or excuse to extend lavish Business Courtesies
to recipients for an improper motivation. Similarly, the sponsorship must be for a genuine business
event. Expenditure on a sponsorship event is not permitted if the discussion of business is not the
main focus of the event.

5: Educational or Training Seminars or Events

In certain instances Doctors are required to attend specialist medical training to learn new clinical
procedures and techniques or to develop existing ones. For example, Doctors may attend
educational or training seminars organised by specialist equipment (e.g., CyberKnife) suppliers or
seminars to inform and educate about clinical safety, which might be held over 2-3 days in domestic
or overseas locations. Where the purpose of the educational or training seminars is to develop the
Doctors’ medical skills in a way intended to benefit HCA Facilities, it may be appropriate for HCA
Facilities to pay attendance fees directly to the organiser and cover reasonable travel and
accommodation costs. Educational or training seminars must not be used as a reason or excuse to
extend lavish Business Courtesies to recipients for an improper motivation, and HCA will cover only
costs that are reasonable, proportionate and not excessive.
In order for HCA to cover the costs for a Doctor to attend an educational or training seminar, the
following requirements must be met:
-Subject Matter of the seminar should be limited to equipment owned by the Facility. While
it may be necessary to train Doctors on a new method of performing an old procedure,
Facilities should not teach Doctors procedures which are new to the Doctor. Facilities will
not provide training or equipment if any one of the stated purposes of the training is to
increase the Doctor’s marketability.
-If the educational or training seminar or event will allow the Doctor to perform and receive
increased payment for a procedure he or she would not otherwise perform and bill for (e.g.,
due to lack of expertise or experience, or bylaws restrictions), then the Facility may only
provide the training or equipment if the Doctor compensates the Facility at a Fair Market
Value (FMV) rate.
– Duration should be limited to a reasonable period of time for each educational or training
event. The reasonableness of time allotted to the training will vary by the complexity of the
equipment.
– Purpose of the educational or training event(s) must be to educate the Doctor in a new
method of providing safer and more effective care.
– Scheduling of the educational or training event(s) shall be at all times the responsibility of
the Facility, not the Doctor. Generally, any training session sponsored by the Facility would
occur on the Facility premises.
– In situations where it is not feasible to provide training to the Doctor at the Facility and the
circumstances fall within the permissible criteria above, the Facility may pay for or
reimburse any reasonable travel expenses related to the educational or training event(s),
including transportation, lodging and food.

Furthermore:

– The Facility CEO must complete an approval form, attached as Appendix 3 (“Educational or
Training Seminar Approval Form”), which contains a breakdown of expenses. Unless
expressly approved in writing by the Executive Director/VP of Legal Services in advance, HCA
should pay applicable registration fees and flight/travel fares directly to the organiser and
carrier/travel agency instead of reimbursing the Doctor for these expenses. Other expenses
(e.g., hotel accommodations, ground transportation, and meals) may be reimbursed as set
forth in the Educational or Training Seminar Letter Agreement. Proposed expense limits
should be consistent with the HMRC worldwide subsistence rates (for applicable rates visit –
https://www.gov.uk/government/publications/scale-rate-expenses-payments-employee-travelling-outside-the-uk).

Any proposed expenses in excess of the HMRC rates should be
explained on the Educational or Training Seminar Approval Form and approved in advance.
HCA will not pay for expenses that are already covered by an event organiser or any person
or organisation other than HCA. For the avoidance of doubt, HCA will not pay Doctors for
their time attending or traveling to an educational or training seminar.
– The Educational or Training Seminar Approval Form must be approved and signed by (i) the
Executive Director/VP of Legal Services and (ii) the Group Chief Finance Officer or the Group
Chief Executive Officer.
–  The Facility CEO must prepare and issue the Doctor an Educational or Training Seminar
Letter Agreement, using the template attached as Appendix 4, containing details of the
authorized expenses pursuant to the approved Educational or Training Seminar Approval
Form.
– The Doctor must countersign and return the Educational or Training Seminar Letter
Agreement to the Facility CEO prior to the event.
– The Facility CEO must provide a copy of the signed Educational or Training Seminar Letter
Agreement to the Executive Director & VP of Legal Services prior to the Doctor attending the
educational or training seminar.
–  A description of the training provided to the Doctor must be disclosed on the website of the
Facility at which the Doctor intends to utilise such training. However, the Facility need not
disclose the cost of the training or the identity of the Doctor(s) concerned.
This provision applies to educational or training seminar attendance. In circumstances where a
Doctor anticipates attending a seminar abroad for the purpose of promoting HCA as opposed to
educational or training purposes, please follow the requirements listed in Section 5 of the Overseas
Business Relationships Policy.

6: Visiting Doctors’ Programme

It is sometimes necessary for Doctors and/or Colleagues to travel abroad to promote HCA or further
business opportunities. Please refer to the Overseas Business Relationships Policy
(HCAUK.GOV.RM.POL.1004) for specific policies and procedures applicable to such trips.

7: Business Courtesies Provided to UK Government Employees

Governments often have strict rules and laws regarding gifts, meals and other Business Courtesies
for their employees. This Policy applies to UK Government Employees. For policies and procedures
applicable to Business Courtesies given to Foreign Public Officials, see the Global Anti-Corruption
Policy (LL.AC.001).
Interactions with individual UK Government Employees pose a special risk under the Bribery Act and
other applicable anti-corruption laws, and it is extremely important that HCA’s dealings with UK
Government Employees are transparent and open.
Before a Colleague may directly or indirectly give, offer, authorise or provide a Business Courtesy or
anything of value to a UK Government Employee, he or she must first ensure that all of the
following requirements are met:

a. The thing of value must be provided only for the purpose of lawfully promoting,
demonstrating or explaining HCA’s services or products, or conducting other lawful and
bona fide business activities (usually limited to appropriate travel and lodging expenses);
b. The thing of value must be provided openly and in a way that does not create the
appearance of impropriety or illegality;
c. The Government Employee must not have directly or indirectly requested from HCA or any
third party anything of value for any individual’s personal benefit;
d. Payment for the thing of value must be provided directly to the provider of the thing of
value (i.e., to the provider of the meal, gift, entertainment or travel) and not directly to the
Government Employee; and
e. The value of the thing or things is reasonable under all of the circumstances.
If all of the above preliminary requirements are met, then the Colleague must then determine
whether he or she must obtain prior joint express written approval of the Executive Director/VP of
Legal Services, the President of Operations and the SVP and Chief Ethics and Compliance Officer (or
designee).
a. If the value is less than or equal to the prescribed limit set forth in the chart below, then the
thing of value may be provided without prior approval.
b. If the value is more than the limit specified, then the prior joint express written approval of
the Executive Director/VP of Legal Services, the President of Operations and the SVP and
Chief Ethics and Compliance Officer (or designee) must be obtained.

United Kingdom Government Employees

If the joint approval of the Executive Director/VP of Legal Services, the President of Operations and
the SVP and Chief Ethics and Compliance Officer (or designee) is required, Employees and
Colleagues must request approval by providing the Executive Director/VP of Legal Services with the
following information:
a. The name, title, and organization of the UK Government Employee;
b. A description of the thing of value proposed to be given to the UK Government Employee;
c. The monetary value of the thing, in Sterling;
d. Any available documentation and/or receipts substantiating such value;
e. The business purpose of the proposed offer or provision; and
f. The proposed date and circumstances of the offer or provision.
On receipt of the above information, the Executive Director/VP of Legal Services will review the
information and provide a summary of the relevant circumstances to the President of Operations
and the SVP and Chief Ethics and Compliance Officer (or designee) of the circumstances, and the
information will be considered for joint express written approval.
Even if prior approval is not required under this policy, if the intended recipient is a UK Government
Employee, documentation and/or receipts substantiating the provision of the thing of value must
promptly be provided to the Executive Director/VP of Legal Services and an appropriate entry be
made on the Business Courtesies Log. The Executive Director/VP of Legal Services will promptly pass
that information on to the President of Operations and the SVP and Chief Ethics and Compliance
Officer (or designee).
Members of the HCA International Team or relevant Facility (as the case may be) will be responsible
for using the Business Courtesies Log in accordance with section B8 of this policy to record Business
Courtesies given to UK Government Employees. In addition, nominal refreshments, such as a cup of
coffee, need not be recorded in the Business Courtesies Log as long as they are of a value generally
less than £9 and not provided to a UK Government Employee more than four times per year.
However, Employees and Colleagues must document on the corresponding expense report the
name, country, and title of any UK Government Employee to whom such nominal refreshments are
provided.

8: Records of Business Courtesies

A Business Courtesies Log shall be used to record Business Courtesies given to all individuals and
their immediate family members, UK Government Employees and to Foreign Public Officials, and all
Business Courtesies must be recorded, except as specifically noted in Section B1 of this Policy.
Facilities must check whether the Annual Limit has been met before offering a Business Courtesy.
Facilities must also keep a register for Business Courtesies received by Colleagues.
Facilities are responsible for updating the Business Courtesies Log within 5 working days after a
Business Courtesy has been provided. The Business Courtesies Log can be found at
http://hcukint05/FCE/Default.aspx
The Business Courtesies Log spreadsheet will be audited by the HCA Financial Controls and
Compliance Department on a bi-annual basis and by the Group Chief Finance Officer on an annual
basis.
For additional information on terms of use of the Business Courtesies Log, please refer to Appendix

9: PRE-AUTHORISATION WHERE BUSINESS COURTESIES EXCEED THE APPLICABLE LIMITS

In the event that a Colleague wishes to offer a Business Courtesy that would exceed the per
instance limit or the Annual Limit, prior to extending the courtesy, he or she must obtain joint
written authorisation from (i) the Group Chief Executive Officer or Group Chief Finance Officer, (ii)
the Executive Director/VP of Legal Services and (iii) the SVP and Chief Ethics and Compliance Officer
(or designee).
In determining whether authorisation should be granted, the Group Chief Executive Officer/Chief
Finance Officer, the Executive Director/VP of Legal Services and the SVP and Chief Ethics and
Compliance Officer (or designee) will consider:
Whether the Facility could reasonably have foreseen that it would like to offer the Business
Courtesy prior to the limit being exceeded.

The size and nature of previous Business Courtesies provided to the recipient by HCA or any
Facility.
The business justification and rationale for the excess and whether it is reasonable and
proportionate.
Whether there is any risk of the Business Courtesy being seen as an attempt to induce or
reward improper conduct by the recipient or another person or actions contrary to the
recipient’s proper duties, regulatory requirements or professional ethics.
Compliance with the Code of Conduct, Global Anti-Corruption Policy and Anti-Bribery Policy.
The Request for Authorisation to Exceed Applicable Business Courtesy Threshold Limit Form is
attached at Appendix 2.

10: Reporting Potential Non-Compliance

Any Colleague who becomes aware of or receives a reasonably credible report that a
potential violation has occurred must promptly make a report to his/her supervisor, to the
Ethics Officer, to the Legal Department or via the Ethics Line at 0808 169 8145 (toll-free).
The Ethics Line enables anonymous reports of potential violations of this and other anticorruption policies, the Bribery Act and other applicable anti-corruption laws.
Any Colleague who fails to report any such warning sign or violation may be disciplined, up
to and including termination of employment. Please refer to the HCA Whistle Blowing policy
available on Grapevine.
No Employee will lose any remuneration, including performance-related bonuses, or other
benefits for reporting in good faith a breach of this Policy.

11: Sanctions

Any Employee who is found to have violated this Policy will be subject to disciplinary action.
Sanctions may range from a warning to termination of employment.
If HCA suspects any Intermediary to have violated this Policy, it will seek the urgent
cooperation of the Intermediary in investigating, and all its legal rights are fully reserved.
Sanctions may include termination of any contracts, removal from HCA’s list of approved
suppliers, civil or regulatory proceedings and reporting suspected crimes to law enforcement
agencies.
The Company reserves the right to report any criminal behaviour to the appropriate
investigating authorities.

RESPONSIBILITIES UNDER THE BUSINESS COURTESIES POLICY

Group Chief Executive Officer
The Group Chief Executive Officer has overall accountability and responsibility for implementation
of this policy.
Group Chief Finance Officer
The Group Chief Finance Officer is responsible for:
Ensuring that the Business Courtesies Logs are maintained by the Facilities and are open for
inspection and scrutiny.
Monitoring the maintenance of the Business Courtesies Logs by the Facilities.
Assessing the potential for actual or perceived risks in respect of Business Courtesies.
Preparing an annual report on Business Courtesies and presenting it to the Group Chief
Executive Officer.
Ensuring that group-wide Business Courtesies given to one recipient and his/her immediate
family do not exceed the Annual Limit.
Executive Director/VP of Legal Services
The Executive Director/VP of Legal Services is responsible for:
Ensuring that the Business Courtesies Logs are maintained by the Facilities and are open for
inspection and scrutiny.
Assessing the potential for actual or perceived risks in respect of Business Courtesies.
Directing the investigation of incidents of potential non-compliance with this Policy.
Ethics & Compliance Officer
The Ethics & Compliance Officer is responsible for:
Investigating incidents of potential non-compliance with this Policy.
Reviewing the Business Courtesies system and processes periodically to minimise the risk of
non-compliance with this Policy.
Communicating to Colleagues the importance of compliance with this Policy
HCA Financial Controls and Compliance Department
Monitoring the maintenance of the Business Courtesies Logs by the Facilities.

Facility Chief Executive Officers
Facility Chief Executive Officers are responsible for ensuring that their staffs are aware of, and
adhere to, this policy.
Facility Chief Financial Officers
Facility Chief Financial Officers are responsible for:
Ensuring all Business Courtesies are logged on the applicable Business Courtesies Log.
Assessing the potential for actual or perceived risks in respect of Business Courtesies.
Reporting any deviations from this policy to the Group Chief Finance Officer and the
Executive Director/VP of Legal Services.
HCA Colleagues
As part of HCA’s commitment to anti-corruption practices, all Colleagues are responsible for:
Assessing the potential for actual or perceived bribery risks in respect of Business
Courtesies.
Raising queries with, or reporting suspicions to, the Executive Director/VP of Legal Services
Complying with this policy and all policies and procedures prescribed by HCA from time to
time.

REFERENCES

HCA Code of Conduct http://www.hcahospitals.co.uk/uploads/manual/CodeWebVersion.pdf.
Policy Number EC.Intl.006 (Entertainment) US Policy
Policy Number EC.Intl.008 (Approval of Gifts in Recognition of Volunteer Efforts)
Policy Number HCAUK.GOV.RM.POL.1004 (Overseas Business Relationships Policy)
Policy Number HCAUS.GOV.SM.POL.001 (General Statement on Agreements with Referral Sources,
Approval Process Policy)
Policy Number HCAUS.GOV.SM.POL.002 (Professional Service Agreements Policy)
Policy Number HCAUK.GOV.SM.POL.018 (Professional Courtesy Discounts Policy)
Policy Number HCAUK.GOV.ALL.POL.105 (Anti-Bribery Policy)
Policy Number HCAUK.GOV.ALL.POL.1003 (Global Anti-Corruption Policy)
Policy Number HCAUS.GOV.SM.POL.007 (Vendor-Promotional Training, Business AssociateSponsored and Honoraria Policy)

APPENDIX 1 BUSINESS COURTESIES LOG – TERMS OF USE
Principles

Access
Access to the database is restricted to:
 Chief Executive Officers.
 Chief Executive Officers’ personal assistants.
 Chief Finance Officers.
 Finance Managers.
 Consultant Liaison Officers.
 GP Liaison Officers.
 Employees nominated by the facility CEO or CFO as responsible for maintaining the Log
 Financial Controls and Compliance team.
 Ethics & Compliance Officer.
 Executive Director/Vice President of Legal Services.
 Group Chief Executive Officer
 Group Chief Finance Officer.
Doctor details
Before a new recipient is entered on the database, it is important to ensure that the recipient does not
already exist within the database.
Entries
Facility Chief Financial Officers are responsible for:
 Entering business courtesies on the Business Courtesies Log within 5 working days of the
expenditure being incurred.
 Ensuring that appropriate documentation exists to support the entry.
Amendments
No users shall be permitted to delete, vary or otherwise alter any of the entries on the spreadsheet.
If users wish to amend their own entries, they will be required to submit justification details to
Financial Controls and Compliance team.
Retrospective entries
No users shall be permitted to insert or otherwise backdate any of the entries prior to the date of use.
Notification of expenditure in excess of cap
The spreadsheet will automatically aggregate value of all expenses as they are entered.
The Register Master will be permitted to prescribe a maximum value of the total expenditure that can
be paid for the benefit of the recipient (“the policy limit”).
Once the aggregate value reaches or exceeds the policy limit, a notification will appear which alerts
the Register Master and the user that the policy limit is being exceeded.

APPENDIX 2 REQUEST FOR AUTHORISATION TO EXCEED APPLICABLE BUSINESS COURTESY LIMIT
FORM please click  HCA courtesies