The Claimant must be kept at the centre of all decisions made when acting as an Authorised User, MRO or an Expert. Each Authorised User, MRO and Expert involved in the process is responsible for promoting the Claimant's best interests in all dealings with the Claimant. You must respect that those interests will vary when providing a service as an Authorised User or MRO or an Expert.

You must not allow your views about a Claimant's sex, age, colour, race, disability, sexual orientation, marital status, pregnancy and maternity, social or economic status, lifestyle, culture, religion or beliefs to impact on the way that you deal with each individual Claimant.

You must maintain and uphold your professional standards at all times when dealing with the Claimant.

You must treat information about the Claimant as confidential and use it only for the purposes for which they have provided it. You must not knowingly release any personal data or confidential information to anyone who is not entitled to it, and you should check that people who ask for the information are entitled to it.

You must keep to the conditions of the Data Protection Legislation and always follow and keep up to date with best practice for handling confidential information. You must also ensure that where you engage a third party’ assistance in preparing reports that they are following such best practice and meeting the requirements of the Data Protection Legislation.

Always maintain high standards of both personal and professional conduct so as to ensure that the general public and all other Authorized Users and Data Contributors will have confidence in you. Your actions should not undermine confidence in the Medco Service.

You must inform MedCo immediately if you have important information about your conduct or competence (including any referral on conduct to a Regulatory Body), or about the conduct and competence of any other MedCo Authorised User or MRO or Expert which comes to your attention, to the extent it is permitted by Applicable Law. In particular you must advise MedCo immediately if you are:

• Convicted of a criminal offence, receive a conditional discharge for an offence or accept a police caution.
• Disciplined by your professional regulator.
• Suspended or placed under a practice restriction because of concerns about your conduct or competence.
• If you have been declared bankrupt, entered into any individual voluntary arrangements or had a County Court judgment issued against you.

MedCo will investigate any report about your conduct and competence in accordance with this policy and the terms of your Agreement. MedCo will take such action as it considers necessary, which may include removing your access to the MedCo Database or your Accredited status and reporting you to your Regulatory Body.

You must make sure that your professional skills, knowledge and performance are of good quality, up to date, and relevant to your scope of practice.

Experts will in any event need to maintain Accredited status as granted by MedCo and will be required to undertake appropriate levels of training, targeted at provision of reports undertaken via MedCo. All Authorised Users and MROs will be required to ensure that they maintain up to date knowledge on Data Protection Legislation and all other relevant Applicable Law.

Accurate records should be maintained of all engagement with the claimant and on all aspects relating to use of the MedCo Service.

Medco have a right to audit and may wish to examine our records.

All authorized Users and Data Contributors will be expected to behave with integrity at all times. This will include (but is not limited to) making full and frank disclosure of any direct financial link that one authorized user may have with a data contributor or vice versa and keeping updated if there are any changes in accordance with Clause 3.2.

Ensuring that referral fees are not requested, paid or received in breach of the legal aid sentencing and provision of offender’s act 2012.

Not providing any misleading information in their dealing with Medco.

Not engaging in any other practice that would undermine the public confidence in Medco, the service, Authorized Users and Data Contributors.

Authorized Users and Data Contributors should ensure that they are up to date with relevant provisions and that the provisions are adhered to. This should include making the relevant fraud checks required by the RTA protocol.

You should ensure that they are familiar with the terms of your Agreement and the MedCo Rules and ensure that these are adhered to. Any revisions will be published, and you should familiarise themselves with any updated versions. MedCo has also published Guidance as to how it will interpret the Qualifying Criteria. Such Guidance will form the basis of audit of MROs all MROs should familiarise themselves with and act in accordance with that guidance as updated from time to time.

Apex expects its staff (including temporary, agency, interim and contractor or consult staff) to be scrupulously impartial and honest in all affairs relating to the Company and their job within it. All staff also bears responsibilities as employees to act as ambassadors for the Company in terms of their general conduct both within and outside the organization. This policy outlines the responsibilities of staff working for the Company.

The duties of an employee are embodied in Common Law and built on by Statute e.g. The Equality Act 2010, The Health and Safety at work Act, The Prevention of Corruption Acts 1906 and 1916 etc.

Under Common Law the duties of an employee are as follows:

• to be ready and willing to work.
• to offer their services personally: for example, must not subcontract the work for which they are employed.
• to take reasonable care in the exercise of that service, including the duty to be competent at work and to take care of the Company’s property.
• to not wilfully disrupt the Company’s business.
• to obey reasonable orders as to the time, place, nature and method of service.
• to work only for the Company in the Company’s time.
• to disclose information to the Company relevant to the Company’s business: for example, that they might know or discover.
• to hold solely for the Company the benefit of any invention relevant to the business on which the Company is engaged.
• to respect the Company’s trade secrets.
• in general, to be of good faith and do nothing to destroy the trust and confidence necessary for employment.
• to account for all benefits – monetary or in kind – received in the course of employment.
• to not give or receive bribes or otherwise act corruptly.
• to indemnify the employer for loss caused by the employee.

United Kingdom Statute places further responsibilities on individual employees in-regards to their own behaviour and their behaviour towards other employees.

The Company has a strict anti-bribery and corruption policy in line with the Bribery Act (2010). A bribe is defined as giving someone financial or other advantages to encourage that person to perform their functions or activities improperly or to reward that person for having already done so.

If an employee bribes (or attempts to bribe) another person, intending either to obtain or retain business for the company, or to obtain or retain an advantage in the conduct of the company’s business this will be considered gross misconduct. Similarly accepting or allowing another person to accept a bribe will be considered gross misconduct. In these circumstances the employee will be subject to formal investigation under the Company’s disciplinary procedures, and disciplinary action up to and including dismissal may be applied.

In addition to the duties placed on employees by Civil and Statute Law. The Company requires its employees to ensure that gifts and hospitality offered by suppliers and potential suppliers of goods and services to the Company are declined. This applies whether the gifts or hospitality are offered within, or outside normal working hours. The only exceptions to this are trivial gifts with a nominal value of less than £10 such as a calendar, diary, chocolates or mugs can be accepted. All other gifts must be politely refused or, if received through the post, returned to the donor with a suitably worded letter signed by the Department Manager.

Employees having official dealings with contractors and other suppliers of goods or services must avoid transacting any kind of private business with them by any means other than the Company’s normal commercial channels. No favours or preferences as regards price, or otherwise, which is not generally available, should be sought or accepted.

The Company intends that when it is necessary for employees to visit conferences, demonstrations and similar occasions, it should bear the travelling and subsistence expenses itself. Exceptions to this general rule will only be permitted with the approval of the Chief Executive.

Where it is evident that the work of the Company will be facilitated, invitations to attend receptions, luncheons may be accepted under the following rules:

• no employee may accept an invitation without first obtaining the approval of the Department Manager.
• in exceptional circumstances, where it is not possible to seek prior approval, the facts should be reported immediately afterwards.
• if addressed personally, such an invitation may not be transferred to another employee, except with the consent and approval of a senior manager as above and with the concurrence of the party issuing the invitation.
• invitations involving attendance outside normal working hours may be accepted only on the authority of the Departmental Manager.
• as a general rule, any officer who has any doubts about the wisdom of accepting any hospitality should decline the offer.

The important difference between, for example attendance in an official capacity at a function organized by the Company or one of its subsidiaries and the acceptance of hospitality from a private individual or firm should be recognized.

Nothing more than a small, low value item such as a calendar, diary, blotter, chocolates or flowers can be accepted. All other gifts must be politely refused or, if received through the post, returned to the donor with a suitably worded letter signed by the Department Manager.

Employees should wear or carry their identity badges whilst carrying out their duties.

At all times confidentiality must be maintained. No information can be released to unauthorized persons or organization. The Chief Executive or other Senior Managers of the Company Will inform employees of those authorized to receive information.

If doubt exists as to the validity of an organization or individuals to receive information. this must be checked with a Senior Manager.

If a personal relationship between two employees develops within the working environment, the onus is on the senior employee concerned to bring this to the attention of his or her manger to confirm that there is no conflict of interest, nor will a conflict of interest arise.

The Company reserves the right to move one of the employees concerned if it deems it necessary to do so.

Outside interests include directorships, ownership, part ownership or material shareholdings in companies, business or consultancies likely to seek to do business with the Apex. These should be declared to the individual’s line manager as should the interests of a spouse/partner or close relative.

It is not the intention of Apex, or this policy, to dissuade employees from participating actively in public duties. It is important, however, that by doing so there is no suggestion to a third party that the employee is acting on behalf of, or with the support of, Apex. To avoid any misunderstanding, no Company employee should permit his or her company affiliation to be noted in any outside organization’s materials or activities without the express written approval of a member of senior management.

Employees should all times conduct themselves in such a way as to enhance the reputation of the Company.

Apex will support employees who become aware of and are willing to report breaches of this policy or who genuinely believe that a breach is occurring, has occurred or is likely to occur within the business. Employees should raise the issue internally with their manager or supervisor or in accordance with the Company’s Policy on Disclosing Information (‘Whistleblowing’).

All staff must make ethical issues an integral part of their daily duties. In the event a potential risk may arise this must be reported to management. All potential issues must be documented in detail.