Group Business Ethics Policy and Code of Conduct

“We strive to provide the right treatment and care to all our patients even when it requires persistence and an extraordinary effort.”

Our Values
As the leading dental care provider in Denmark, our goal is to provide high-quality dental service and care to all our patients and through this improve our patient’s general dental health. We strive to provide the right treatment and care to all our patients even when it requires persistence and an extraordinary effort. We want to lead the industry and help create increased transparency about quality standards.

We will achieve this through our mission of:

  • Prevention and treatment by ensuring that as many of our patients on a regular basis visits our clinics and receive precisely the right treatment they need and which ensures the best dental health and general health – nothing more, nothing less.
  • Delivering care by ensuring the best and safest patient experience in our clinics and by making a special effort to increase the dental health of vulnerable groups.
  • Leading the dentist industry through education, new technology and create increased transparency about quality standards in the industry.
  • Attracting and retaining the industry’s best employees by offering development, professional communities, a healthy and good working environment, with great opportunities for specialization.

Purpose and Scope
This Group Business Ethics Policy (the “Policy”) shall provide a framework for Tandlæ Group’s employees and the business partners of our business principles and ethical standards that we expect to be respected in our daily activities. The Policy shall convey the principles and values of Tandlæ Group. It shall ensure that we live up to our social corporate responsibility in everything we do so that we can be proud of our culture and achievements.

Compliance with this Business Ethics Policy
This Policy applies to all employees and business partners of Tandlæ Group, regardless of their status, location and the nature of their work. Certain topics covered by this Policy will be further governed by specific regulations that further detail the behaviour expected for these topics. Violations of this Policy and any further regulation will not be tolerated, and disciplinary action may be taken in cases of breaches. Failure to act as is required is seen as unethical and also regarded as a contravention of the Policy.

Health and Safety
Our human capital is the most valuable asset we have, as our employees are our greatest strength. Tandlæ Group are therefore committed to creating a friendly and safe working environment where every employee feels respected and can contribute to achieving the best possible patient satisfaction. At Tandlæ Group we adhere to the highest professional standards when it comes to patient safety. Our employees are trained on safety issues to ensure that our patients can benefit from sage and effective medical treatments. Our internal safety processes and procedures are monitored, reviewed and adapted, as we take our responsibility as a healthcare provider serious. We are in close collaboration with the national health authorities as well as pharmaceutical and medical devices companies to report adverse events occurring in our daily practice. We aim to help improve the professional equipment we need to provide high-quality dental services and minimize the risk of invasive treatment as far as possible.

Our Patients
We are dependent on our patients. Our patients are the foundation of our success. Our goal is to improve our patient’s dental health by providing high-quality dental service and care. We strive to improve patient safety and satisfaction to provide the best possible dental care.
We expect that our employees are committed to apply the highest professional standards when providing services to our patients.
We expect that our employees inform our patients of all medical and financial aspects of a recommended treatment enabling our patients to make an informed decision. All medical treatments performed by our employees shall be in the best interest of our patients and we respect our patients’ wishes and rights at all times – provided these are in line with medical and ethical standards. We do not recommend or perform unnecessary treatments and are committed to fair and transparent billing practices.
All complaints raised by any of our patients are taken very seriously and such complaints are thoroughly investigated, discussed and handled with the patient who raised the complaint.

National Authorities and Public Officials
The dental industry is highly regulated, and we interact with the authorities on a daily basis. When interacting with the authorities our employees shall abstain, from any behaviour that might be perceived as illegitimate behaviour to gain an improper advantage. Tandlæ Group do not try to gain an improper or unfair advantage by offering or promising anything of value to a public official to influence his or her decision and we should further not follow such a request made by a public official.

Business Partners
In order for us to be able to provide high-quality dental services, we need first-class dental equipment. It is our policy to only work with reliable, trusted and reputable industry partners which share the same values as we do. We choose our industry partners and products based on their ability to fulfil our patients’ medical needs, the quality of products, their reliability and reputation, the partners’ values, their compliance program and price. We expect from our partners to comply with this Policy, our Supplier Policy of Conduct as well as all applicable laws and to adhere to the highest ethical standards.

Fair competition is essential for Tandlæ Group and we do not engage in unfair or unethical business practices nor anti-competitive discussions or agreement with our competitors. We aim to compete based on the merits of our service.

Compliance with Laws and Regulations
We are committed to an ethical, legal and compliant way of doing business. Our employees are, responsible for understanding and respecting the applicable laws and regulations in their area of activity. We also expect that our business partners suppliers must comply with all laws, regulations and standards applicable to their area of business, and the products and services that they provide to Tandlæ Group shall conform to all applicable requirements, and we expect our suppliers to have a program in place to ensure and monitor compliance with the applicable laws and regulations.

Business Courtesies and Gifts
The tandlæ Group is committed to fair and ethical business practices. Business courtesies – such as invitations, gifts or meals – are accepted business practices in Denmark. However, any behaviour that might be perceived as unduly influencing another person to gain an improper advantage is strictly prohibited. Tandlæ Group does not try to gain an improper or unfair advantage by offering or promising anything of value to someone to influence his or her decision. Likewise, we expect our suppliers and business partners not to unduly influence our employees to gain an improper advantage at the expense of Tandlæ Group.

Discrimination and Harassment free Environment
Passion for dental care and the best patient experience is paramount to us. This not only requires us to apply the highest professional standards when it comes to the treatment of our patients but also to provide our employees with a safe, respectful and friendly working environment, free from harassment and discrimination. We do not tolerate harassment or discrimination of any kind, whether it is towards patients or employees. We also do not tolerate any behaviour that creates a hostile working environment, aggressive pressure or intimidation.
Harassment or discrimination in the meaning of this Policy includes any unwanted or unwelcome attention or discriminatory conduct based on race, colour, religion, citizenship, national origin, gender, sexual orientation, disability, pregnancy or other characteristics provided by law. Any such harassment of patients or employees will result in disciplinary action.

Confidentiality and Privacy
As we are a dental chain, we have access to sensitive health data concerning our patients. Therefore, protecting our confidential information as well as the privacy of our employees and patients is very important to us. All our employees must understand the importance of privacy, data protection and confidentiality. We do not tolerate the invasion of our patients’ privacy by our employees. All employees and any consultants of Tandlæ Group must protect confidential patient data, company and business information and not disclose such information to any third party outside the Tandlæ Group. In particular, the confidentiality of our patients’ medical records is paramount to maintain the patients’ trust in our services and Tandlæ Group. We restrict access to patient information as appropriate and use it only as necessary for legitimate business purposes. Our collection, use and storage of such information complies with the General Data Protection Regulation (GDPR) and the laws of Denmark.

Asset Protection
We provide our clinics with state of the art infrastructure and dental equipment to enable our employees to provide first-class dental services. We expect our employees to use such equipment with diligence and care and take reasonable precautions to protect such equipment from loss, damage or theft. Dental equipment shall always be used and maintained by their instructions and processes to ensure proper use and patient safety. Such equipment must not be used or removed for any other purpose than purposes of Tandlæ Group, in particular not for private or third-party purposes.

Conflicts of Interest
We expect our employees to avoid any conflict of interest between their own interests and those of Tandlæ Group. When making a decision affecting Tandlæ Group, personal interests may not adversely affect such decision at the expense of Tandlæ Group.
A conflict of interest arises when a person’s private interests interfere or have the appearance of interfering, in any way with the legitimate interests of the Tandlæ Group.

Community and Environment
As the leading dental care provider in Denmark, we recognize our responsibility towards the environment and, therefore, we use our natural resources in a responsible, sustainable and effective manner. We ensure sustainable waste management and recycling.

Use of Social Media
We see social media as a powerful tool to stay connected with, provide information to and interact with our patients. We use Facebook, Instagram and LinkedIn when communicating with our patients, employees, business partners and other stakeholders. Any posts on such channels must always comply with our values, this Policy and all other policies of Tandlæ Group.

We appreciate that our employees also use social media in their private life. However, as every post made by an employee in his/her private life may also potentially affect Tandlæ Group as an employer, we encourage employees to responsibly use social media and use common sense and sound judgement when posting any material and/or information on social media. It is strictly prohibited to post any work-related confidential information on social media. If any patient information, such as patient pictures, shall be posted on social media, the written consent of the patient needs to be obtained before any such post. Tandlæ Group do not tolerate that employees expose other employees or patients on social media channels. We generally expect from our employees to responsibly use social media and adhere to the values and conduct described in this Policy.

Whistle Blower
We encourage every employee of Tandlæ Group to report any concern relating to a non-compliant behaviour to his/her immediate manager, Tandlæ Group HR Department or Tandlæ Group Legal Department. Any concern raised, and any complaint filed by an employee will be taken seriously and will be investigated. The board of directors, as well as the management of Tandlæ Group, will support any employee who in good faith raises any concerns or reports a suspected breach of this Policy. Tandlæ Group does not tolerate any retaliatory action if concerns are raised in good faith.