Corporate Governance

General Legal Information

The Malaysia Healthcare Travel Council (MHTC), under the purview of the Ministry of Health Malaysia, maintains this website for the convenience of the public. By accessing and using the information and/or materials downloaded from this site which are owned and/or operated by MHTC or its affiliates, you are agreeing to comply with and be bound by the following terms of use, which may be updated and amended from time to time.

Links to Third-Party Sites

The links in this website will allow you to leave the MHTC website. The linked websites are not under the control of MHTC and MHTC is not responsible for the contents of any linked site or any link contained in a linked site, or any changes or updates to such sites. MHTC provides these links as a matter of convenience to users and is not to be implied as an endorsement of the linked site.

Listed Healthcare Services

The listed hospitals and healthcare professionals can be contacted directly regarding any query, consultation or treatment services through their listed mode of contact. Their services can be availed as per their individual terms and conditions.

Discrepancies

In case of Medical discrepancies or conflict for importability of malpractice carried out by the patient, all concerned parties establish and agree that all judicial action must be carried out by the patient towards the medical professional / healthcare center / hospital and that action will not be extended towards www.mhtc.org.my, its managing company or any of its directors and employees as it is a body that puts at the disposition of the patient different professional options through listing their services without exercising medicine professionally.

BY USING THE WEBSITE YOU SIGNIFY YOUR ACCEPTANCE TO OUR TERMS AND CONDITIONS. SHOULD YOU DISAGREE WITH THE ABOVE TERMS AND CONDITIONS, IT IS ADVISED THAT ITS USE IS TERMINATED.

Introduction

Malaysia Healthcare Travel Council (hereinafter referred to as “MHTC” or the “Company”) Anti-Bribery and Anti-Corruption Policy (hereinafter referred to as the “Policy”) is a reference document of MHTC on policy matters relating to the prevention of bribery and corruption. It is not intended to be one-size-fits-all that will provide solutions to all issues.

The Board of Directors of MHTC and the Management of MHTC recognise its role to promote culture of integrity and to ensure that business activities and operations shall always be conducted in an honest and ethical manner.

Commitment

MHTC has a zero-tolerance approach towards all forms of bribery and corruption and is committed to act with the highest level of integrity in its business dealings and relationships in all jurisdictions that it operates.

The Board of Directors of MHTC and the Management of MHTC are committed to implementing and enforcing effective actions to combat bribery and corruption which are punishable offences in accordance with the anti-corruption laws.

MHTC has developed a framework which includes the policies, procedures, risk assessments, due diligence on third parties and associated persons, and employee training programme.

Compliance with the Policy constitutes conditions of employment and further constitutes conditions of providing services by Business Associate to MHTC. Each such person agrees to be bound by the provisions of this Policy as mutually agreed by the Business Associates in MHTC’s standard contracts and/or agreements.

Gifts, Hospitality and Entertainment

It is MHTC’s policy that no Employee or his immediate family members shall accept any form of gifts (except for Corporate Gifts) or favours from Business Associates, if it could be perceived as intended to, or likely to, influence him in the fair, impartial and efficient discharge of their duties. Gifts should only be offered to and received in connection with a customary business or cultural occasion (cash, loans, kickbacks or the equivalent advantages are absolutely prohibited). For avoidance of doubt, Gifts must not exceed RM500.00 and in any event, must not occur more than 3 times a year with the same person or organization.

Employees of MHTC shall not accept any gratuitous entertainment from any of the Business Associates.

In the event Employees of MHTC receive any gifts from clients, customers, business partners, or any other party having business dealing with the Company, the Employees are required to declare the same to their respective Head of Department and refer to the steps and procedures set out in the MHTC’s Employee Code of Conduct to avoid ambiguity, allegations and conflict of interest.

Facilitation Payments and Kickbacks

MHTC does not make and will not accept facilitation payments or “kickbacks” of any kind by any of its Employees and Business Associates. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.

Kickbacks are typically payments made in return for a business favour or advantage. All MHTC’s Employees and Business Associates must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by MHTC.

Donations and Sponsorships

No donation shall be made or offered by the Employees of MHTC.

Sponsorships are permitted in carrying out the business activities of the Company and in accordance with the Limits of Authority. However, the Company prohibits the giving and receiving of donations and sponsorships to influence business decisions.

Conflicts of Interest

Conflicts of interest arise in situations where there is a personal interest that could be considered to have potential interference with objectivity in performing duties or exercising judgment on behalf of MHTC. All Employees should avoid situations in which personal interest could conflict with their professional obligations or duties. Employees must not use their position, official working hours, Company’s resources and assets, or information available to them for personal gain or to the Company’s disadvantage.

In situations where a conflict does occur, Employees shall declare such matter in any form or format as they please to the respective Heads of Department as per the Employee Code of Conduct.

Record-Keeping

MHTC must keep financial records (together with relevant supporting documents) and have appropriate internal controls in place, which will evidence the business reason for making or accepting payments or gifts to or from third parties. The financial records must be retained for at least seven years and produced on request by the custodian of the process.

Employees must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties comply with all policies and guidelines and specifically record the reasons for the expenditure.

All accounts, invoices, other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, must be prepared and maintained with accuracy and completeness.

No accounts must be kept “off-book” or considered “off-record” to facilitate or conceal improper payments.

How to Raise Concern

All Employees or Business Associates are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage if he believes or suspects that a conflict with this Policy has occurred or might occur in the future.

Training and Communication

Training on this Policy forms part of the induction process for all MHTC’s new and existing Employees.

Monitoring and Review

Heads of Departments, Top Level Management and Audit Committee must monitor the effectiveness and review the implementation of this Policy regularly considering its suitability, adequacy and effectiveness. Any improvements identified shall be made as soon as possible.

Internal control systems and procedures shall be subjected to regular reviews or audits to provide assurance that they are effective in countering bribery and corruption.

All MHTC’s Employees are responsible for the success of this Policy and should ensure they use it to disclose any suspected danger or wrongdoing.

Sanctions for Non-Compliance

Non-compliance as identified by the audit and any risk areas identified through this and other means should be reported to the Top-Level Management and/or Audit Committee in a timely manner in accordance with the level of risk identified.

MHTC regards bribery and acts of corruption as serious matters and will apply penalties in the event of non-compliance to this Policy. For Employees, non-compliance may lead to disciplinary action, up to and including termination of employment.

For Business Associates, non-compliance may lead to penalties including termination of contract. Further legal action may also be taken in the event that MHTC’s interests have been harmed or damaged as a result of non-compliance by individuals and organisations in accordance with provision of the agreements.

This notice is issued pursuant to the Malaysian Personal Data Protection Act 2010 (“Privacy Notice”) and the principles which will apply to our processing and disclosure of the personal data to the extent permissible under the law. We implement strict security standards to maintain the safety of your personal information and to prevent unauthorised access.

1. What is personal data?

Personal data shall have the meaning ascribed to it in the Malaysian Personal Data Protection Act 2010.

2. What information we collect?

Information you give us via provided online form, email, newsletters or surveys.

Information we collect automatically, including but not limited to: -

  • when you interact with us interaction through our website by using cookies or tracking technologies; or
  • when you interact with us during events, talks, programmes and webinars organised by us and/or our partners; or
  • when you share an article or post a comment or other content with a friend/contact through social media about us; or
  • web analytics services, including third-party services such as Google Analytics.

By providing your or another individual’s personal data to us, you confirm that you and such individual consent to our collection, use and disclosure of the personal data in accordance with this Privacy Notice. Please do not provide us your personal data if you do not consent to the use and disclosure of your personal data in such manner.

3. Why do we collect personal data?

We collect and process your personal data for the following purposes:

  • optimising the performance and user experience of our sites;
  • operating, evaluating and improving our business;
  • conducting research and analysis;
  • to provide you with personalise content;
  • to process and respond to your enquiries;
  • to confirm or update information provided by you
  • to communicate with you;
  • to invite you to the events, talks, programmes and webinars organised by us;
  • for marketing and internal administrative purposes;
  • for the purpose of complying with the laws and regulations including requirements of any government or authorities or court of law; and
  • for other legitimate business purposes.

4. Disclosure of personal data

We will keep confidential your personal data and we will not disclose your personal data to any unaffiliated third party without your consent. You hereby give your consent to us disclosing your personal data to the following parties, including but not limited to, government agencies, statutory authorities and/or industry regulators whom we are compelled or required to do so pursuant to any law.

5. Your rights of access and correction

You may access, request correction or update to your personal data, withdraw (in full or in part) your consent given by contacting us. Please allow us a reasonable time to respond and effect any change.

6. How long do we retain data?

We keep your personal data for as long as is necessary for the purposes for which it is processed. These periods vary depending on the nature of the information and your interactions with us. When the purposes for which we processed your personal data have concluded, we will either permanently delete or destroy the relevant personal data or anonymise it, in a manner that ensures individuals are no longer identifiable.

7. Changes to this Privacy Notice

We may review and update this Privacy Notice from time to time to reflect any necessary changes in compliance with the relevant laws and regulations. As it is generally not practicable to notify you of the changes to this Privacy Notice, the latest version will always be posted or available on this website. It is your responsibility to check this Privacy Notice before you submit additional personal data to ensure that you are aware of the latest version. By continuing to access to this website, deal with us and/or instruct us in the course of our services to you, you are deemed to have consented to the updates to this Privacy Notice.

8. Email Communication

It is our usual practice to send all official communications between ourselves and clients or other third parties using email accounts from the domains “@mhtc.org.my”. We have a strict policy of NOT issuing unsolicited emails and DOES NOT issue email soliciting engagements. Any such email purporting to be from us is a case of identity theft by a person or persons unknown to us. If you have received an email from any other domain, that communication does not relate to the official business of us, shall be understood as neither given nor endorsed by us. We are not liable for the content of such communications, or for the consequences of any actions taken based on such communications, regardless of any claims of association with us or any of our partners.

9. What happens when I link to another site?

This website contains links to other websites. This privacy policy applies only to our site and you should be aware that other sites linked by this website may have different privacy policies and we highly recommend that you read and understand the privacy statements of each site.

10. Questions and contact information

If you have any questions regarding this Privacy Notice, please contact us by email at [email protected]

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