FREQUENTLY ASKED QUESTIONS

• Why is it important to file a report?
• How and where can I report misconduct?
• What should I report?
• Can I be subject to disciplinary measures if I report misconduct?
• If I have been a participant in misconduct, can I report it?
• Where can I find out if there is a Company policy that regulates a specific issue, or how to apply a certain policy?
• What happens when I contact the Ethics and Compliance Help Center?
• Can I file a report anonymously? What are the guarantees?
• What happens after I file a report?
• Through what means can I attach information on the events reported?
• How long does it take to investigate a complaint?
• When will I know the results of an investigation?

Why is it important to file a report?

Immediate reporting of possible misconduct allows us, as a Company, to learn about situations that threaten our integrity value, and evaluate the assignment of said report to the corresponding team in order to initiate an investigation under the principles of Non-Retaliation, Confidentiality and Due Process. In this way, and as the case may be, the Company may take necessary measures to resolve the reported situation.

How and where can I report misconduct?

To report possible misconduct, such as violation of Company policies, you can contact your immediate superior, Company manager, Human Talent area or the Compliance area. If you prefer to contact other people, or if you have reported a situation and do not believe it has been investigated or resolved, you can contact the Ethics and Compliance Help Center or submit your report through this website in the section “Report a Complaint”. The Ethics and Compliance Help Center is available 24 hours a day, seven days a week. The Ethics and Compliance Help Center staff do not have Caller ID available on their phones, so no matter where you call from, you cannot be identified. The Help Center website does not track computer names or IP addresses, so online reports cannot be linked to any particular person.

Additionally, if you wish, you can also make your complaint to the following email: centrodeayudaetica@clinicadelcountry.com.

What should I report?

The Company expects its collaborators and third parties to report possible breaches of our laws, rules, internal regulations, policies and procedures or misconduct. Collaborators or third parties who are aware of any situation that may put the integrity and reputation of the Company at risk, must report the facts immediately.

Can I be subject to disciplinary measures if I report misconduct?

No, as long as your report is made in good faith. The Company has established a non-retaliation policy, where no disciplinary measures may be taken for the fact that a person reports irregularities or participates in an investigation process, as long as this report is made in good faith and within a spirit of collaboration.

For more information, check our Non-retaliation Policy.

If I have been a participant in misconduct, can I report it?

Yes, you can make a complaint, and the Company will evaluate if it carries out an investigation, framed within due process. In this sense, and where appropriate, the Company cannot guarantee that disciplinary measures will not be taken for your actions, but it will take into consideration the fact that you have reported it, which may mean a less strict disciplinary measure.

Please note that failure to report misconduct is, in turn, a violation of our Company policies.

Where can I find out if there is a Company policy that regulates a specific issue, or how to apply a certain policy?

You can contact the Compliance Officer of Banmédica Colombia through the following email: centrodeayudaetica@clinicadelcountry.com; or if you prefer, you can call the Ethics and Compliance Help Center who will receive the information and assign its resolution to the competent team.

What happens when I contact the Ethics and Compliance Help Center?

The Company has contracted a call service, called EthicsPoint. Call center staff of this provider are trained to ask questions that will help provide the Company with information necessary to carry out an investigation and, where appropriate, guide the facts that you report.

The provider's staff will not be able to resolve all of your concerns on the initial call. An online report will be prepared with the information you provide and will be sent to the Company´s Compliance area. When you report an irregularity or problem, you will be assigned a report code and password, which you must keep, since it is the only way by which you can monitor the status of your report, supplement information provided or answer questions that may be asked by the Compliance area.

Can I file a report anonymously? What are the guarantees?

Yes, you can report anonymously. If you do so, the Company will take all necessary measures to protect your identity, even if your name is mentioned. The call will not be registered, and we will not know the number or place of the caller. If your report is made through this website, we inform you that it is safe and protected by the latest encryption technology. However, there are some considerations you should take into account:

- The defendant could discover who filed the complaint. For example, if you report that another collaborator does something improper, it is very likely that we will ask said person for their version of the facts. Obviously, sometimes the person can guess who made the complaint.

- If you do not identify yourself, there is the possibility of not being able to adequately respond to your complaint or investigate it, unless you provide us with some means of communication to obtain more information.

- If you wish to identify yourself, remember that we will keep your data confidential, so we will take all measures to ensure your condition of anonymity, except when requested by a competent authority.

What happens after I file a report?

All complaints received related to breaches of laws, rules, internal regulations, policies and procedures or misconduct, will be investigated according to what is established in the internal procedure.

Calls or complaints received through the Help Center are sent to the Compliance area, which evaluates whether to undertake the development of an investigation. If so, and depending on the type of complaint, the Compliance area will be in charge of said investigation or will assign the case to a suitable team, which may be Human Talent, the Health area, the Legal area or other areas, as appropriate.

Through what means can I attach information on the events reported?

You can use this same website to include or attach information that may help the investigation. If you prefer to use other means, we recommend sending your information to the following email: centrodeayudaetica@clinicadelcountry.com.

How long does it take to investigate a complaint?

The Company takes complaints filed seriously and is committed, which is why it has established an average term for the resolution of a complaint of no more than 30 business days. However, and depending on the complexity of the process, sometimes an investigation can take longer than expected.

When will I know the results of an investigation?

At the end of the investigation, the Company will notify you through the Help Center that the investigation is complete and that an appropriate action has been or will be taken. In accordance with our policy of confidentiality and protection of personal data, in some cases, you will not receive details of the findings of the investigation, nor of the measures taken, including any disciplinary action against a collaborator for breaches of laws, rules, internal regulations, policies and procedures or misconduct. If you believe the problem continues, we request you contact Compliance again.