- Anti-Bribery and Anti-Corruption Policy
- Personal Data Protection Notice & Policy
- Whistleblowing Policy and Procedure
General Legal Information
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.
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.
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.
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.
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.
At all times during the engagement of our services, Malaysia Healthcare Travel Council (“MHTC”) prioritises the safety of your personal information. We are committed to ensuring your personal information and your sensitive personal information provided to us remain secured and safe from any unauthorised and unwanted access.
This Personal Data Protection Notice sets out how we collect, use, access, transfer, store and handle (“process”) your Personal Information under the Malaysian Personal Data Protection Act 2010.
1. What is Personal Information / Sensitive Personal Information?
1.1. Under Section 4 of the Malaysian Personal Data Protection Act 2010:
- personal information (or personal data) means any information that could directly or indirectly help distinguish, identify or contact you. These may include (but is not limited to) your name, personal contact number, picture, NRIC number, passport number, images recorded by the closed-circuit television (CCTV) or location tracking/GPS information and sensitive personal information;
- sensitive personal information (or sensitive personal data) means any personal information consisting of information relating to your physical or mental health or condition, your medical history, allergies and diagnostics.
2. Where do we get your Personal Information?
2.1. MHTC collects your personal information directly from you or indirectly from your legal representatives (family members or next of kin), agents (such as medical tourism agents), outsourcing partners, etc, when you submit any completed enquiry forms or registration forms to us through various means, including online and physical copies at public venues or any other premises, web analytics services such as Google Analytics and comments and shares you posted about MHTC on social media.
2.2. By providing your or another individual’s personal information to us, you or the person which you are representing consent to our process of the personal information. If you do not consent for us to process the personal information, you may refrain from providing us with personal information of you or the person which you are representing.
3. Why do we collect Personal Information?
3.1 Subject to any laws and regulations (including guidelines and/or by-laws) imposed on us, we process your personal information to undertake your requested commercial transactions, including (but not limited to):
- performing a contract to which you have entered with MHTC;
- fulfilling your request of entering into a contract with our affiliated hospitals and/or any other medical healthcare facilities;
- to administer and communicate with you in relation to our services, webinars, talks, and/or events;
- for collaborations with a third party to advertise and market products and services to you
- to conduct internal marketing analysis and customer patterns and choices;
- to comply with MHTC’s legal obligations in the course of our business;
- to optimise the customer and user experience of MHTC sites;
- for MHTC’s internal records management;
- to allow affiliated hospitals and/or any other medical healthcare facilities to contact you for further enquiries and/or performance of the relevant contract;
- to support research and innovation of our products and services;
- for insurance purposes;
- to send you season’s greetings, special occasion messages or other similar communications;
- to ensure the contents on MHTC’s website are up to date and represented in the most effective manner for you and your computer and/or device
- for internal investigations, audit or security purposes;
- to create a more personalised experience for you to enhance customer experience;
- to store and carry out data analytics processes; and
- for other legitimate business purposes.
3.2. You are obligated to provide us with the personal information which we have requested for unless stated otherwise. Should you fail to provide us with such requested information, we may be unable to process your request, enquiry and/or provide you with our services.
3.3. Where you have consented to receive any marketing or promotional updates from MHTC and wish to opt-out from our updates, you may select the “unsubscribe” option provided in MHTC’s email blasts or contact us at our details below.
4. Disclosure of Personal Information
4.1. Entities within MHTC
Your personal information may be transferred to entities (in or outside of Malaysia) within MHTC in the provision of any services related to the purposes stated above. Access to your personal information shall be limited to our staff, employees and/or agents who are contractually required by their scope of work to process your personal information.
4.2. Disclosure to Third Parties
Your personal information (including sensitive personal data and non-sensitive data) may be processed by relevant third parties (in or outside of Malaysia) pursuant to the relevant contractual relationship. For example, we may appoint third-party providers to engage in the purposes stated above.
This includes (but is not limited to) disclosure to:
- professional advisors;
- service providers;
- conference/training/event organisers;
- travel agencies;
- airline companies;
- rehabilitation and well-being centres;
- technology and healthcare service providers;
- insurance companies;
- law enforcement agencies, including the local police;
- relevant government authorities, statutory authorities i.e. Ministry of Health;
- relevant accreditation bodies such as the Malaysian Society for Quality Health;
- local council and industry regulators;
- our affiliates who may jointly provide the service requested for (such as third-party hotels, transportation services, our affiliated hospitals and our other affiliated healthcare providers.
4.3. In the event of a proposed or actual sale of a business, disposal, acquisition, merger or re-organisation, your personal information may be required to be disclosed or transferred to a third party as a result of or to facilitate the aforementioned events.
4.4. Transfer of your personal information outside Malaysia.
- It may be necessary for us to transfer your personal information outside Malaysia if any of the third parties mentioned above are located or have processing facilities in countries outside of Malaysia.
- By providing us with your or another individual’s personal information, you or the individual which you are representing consent to us transferring your or his/her personal information outside Malaysia to such third parties in order to undertake the purposes stated above.
- We shall implement strict standards and security to ensure that such third parties are contractually bound to safeguard your personal information and can only process your personal information under our instructions and/or request.
5. What happens when you access our website?
Our website may provide links to other sites for your ease of convenience. Our Personal Data Protection Policy applies solely to MHTC’s website and does not apply to any third party websites. We recommend you to read and understand their respective Personal Data Protection Policy if you visit any linked websites.
5.2. Location enabled products or applications
We may utilise data analytic tools to help us build and improve on our customer experience by collecting your information.
6. Your rights of access and correction
At all times during the processing of your personal information, you are entitled by right to access, correct and update any of your personal information. Should you wish to do so, you may contact us at our contact information set out below. Please allow us reasonable time to respond and effect any requested changes.
7. Limiting the processing of Personal Information
If you would like to make further enquiries on how to limit the processing of your personal information, make a complaint or have further enquiries regarding the processing of your personal information, you may contact us at our contact information set out below.
8. Changes to this Personal Data Protection Notice
We may review and update this Personal Data Protection Notice from time to time and without prior notice. Any changes made will supersede any and all previous versions. We encourage you to check our Personal Data Protection Notice page before you submit additional personal data to ensure that you are aware of the latest version.
9. 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 represent and/or relate to our official business and neither will it be deemed to be 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.
10. Questions and contact information
You may contact our [Customer Service Officer] at:
Malaysia Healthcare Travel Council
Call Centre: +603 2726 8688
Toll Free- Inside Malaysia: 1-800-188-688
Email: [email protected]
- Malaysia Healthcare Travel Council (“MHTC”) is committed to conducting business dealings with integrity and in compliance with applicable laws including but not limited to Whistleblower Protection Act 2010, Companies Act 2016, and Malaysian Anti-Corruption Commission Act 2009. If multiple documents contradict one another in relation to the same subject matter, then the more stringent provisions shall apply.
- MHTC encourages actual or potential malpractice or misconduct to be reported, in good faith, without fear of reprisal.
“Board” means the Board of Directors of Malaysian Malaysia Healthcare Travel Council including all independent and non-independent directors, executive and non-executive directors and shall also include alternate or substitute directors (if any).
“Business Associate” means an external party with whom MHTC has, or plans to establish, some form of business relationship including but not limited to members, agent, partners, vendors, service providers, potential service providers, suppliers, contractors and/or any party which the MHTC has any business dealings.
“Employees” shall have the meaning ascribed to it the Employee Code of Conduct.
“GC” means Governance Committee of Malaysia Healthcare Travel Council.
“He/him/his” refers to the general gender.
“Improper Conduct” means any unethical behaviour, malpractices, illegal acts or any other wrongful or improper conduct within MHTC which if proven, constitutes a disciplinary offence or a criminal offence. This includes, without limitation, any actual, attempted, or suspected bribery or corruption or non-compliance with the MHTC ABC Policy documents.
“MHTC” means Malaysia Healthcare Travel Council.
“Reprisal” means disciplinary measures, demotion, suspension, termination of employment or service or any other retaliatory action.
“WPA” means the Whistleblower Protection Act 2010 and includes any amendments from time to time.
“Whistleblower” is an individual, who may or may not be an Employee of MHTC, who makes a confidential disclosure of an Improper Conduct that relates to any Employees of MHTC or its operations.
“Whistleblowing” is the act of disclosing an Improper Conduct
- The MHTC Whistleblowing Policy and Procedure (hereinafter referred to as the “Policy”) is a reference document to protect the whistleblower who lodged a report or complaint, provided the report is made in good faith (“Whistleblower”) even if the report made proved to be inaccurate or unsubstantiated.
- Anyone engaging in retaliatory conduct against the Whistleblower may be reported to the relevant authorities and may be subjected to enforcement actions by the relevant authorities under the WPA
- Protection to the Whistleblower will not be accorded by MHTC in the following circumstances:
- the Whistleblower himself has participated in the Improper Conduct.
- the Whistleblower himself willfully made in his disclosure of Improper Conduct a material statement which he knew or believed to be false.
- the disclosure of Improper Conduct principally involves questioning the merits of government policy.
- the disclosure of Improper Conduct is made solely or substantially with the motive of avoiding dismissal or other disciplinary action.
- The Policy applies to the Employees, the Board, Business Associates and any third parties who have business dealings with the Company.
5. MAINTENANCE OF THIS POLICY
- This Policy is to be reviewed and updated as and when there are changes made to the legislation or to the policies of MHTC to reflect its current practices.
- The Legal and Compliance Department of MHTC as the owner of this Policy is responsible for keeping this Policy current and this Policy will be updated to reflect any changes to the same to meet operational and regulatory requirements. This Policy, where applicable, shall be read together with other existing policies, procedures, guidelines, and applicable laws issued by the relevant authorities in Malaysia.
- This Policy will be published and made accessible to Employees and on the MHTC website(s)
6. PROTECTION AND CONFIDENTIALITY
- The Whistleblower’s identity and reports will be protected and kept confidential unless otherwise required by applicable laws or for purposes of any proceedings by or against the Company. A report will only be disclosed to those who are authorised to carry out an investigation into matters relating to the report. Any kind of whistleblowing must be disclosed and made in good faith.
- Malicious reports by the Employee will be treated as gross misconduct and if proven, may lead to disciplinary action in accordance with the Employee Code of Conduct. Malicious reports by the Business Associates or any third parties will be handled in accordance with the applicable laws.
7. HOW TO REPORT
Employees, Business Associates, and third parties should report their concerns regarding Improper Conduct at the earliest opportunity so that corrective actions can be taken as soon as possible. Employees, Business Associates, and third parties have the option to make whistleblowing reports in strict confidence through any of the following channels:
- Whistleblowing reporting form that will be made available at https://www.mhtc.org.my/corporate-governance/ or in Appendix 1 of this Policy.
- Email to MHTC Governance Committee: [email protected].
- Letter to MHTC Chief Executive Office / Chief Operating Officer.
- Anonymous disclosure may be considered at the discretion of the recipients. In exercising this discretion, the factors to be taken into account would include: i) the seriousness of the issue raised by the Whistleblower; ii) the credibility of the concern; and iii) the likelihood of confirming the allegation from other sources.
- The Whistleblower shall need to demonstrate that there are reasonable grounds for his concerns and provide sufficient information for the Governance Committee (“GC”) to take appropriate steps.
- The identity and personal information of the Whistleblower and the alleged wrongdoer may only be revealed to persons involved in the investigation process.
- Preliminary Analysis
- the GC will convene within 2 working days to acknowledge the report received and conduct a preliminary analysis to authenticate the report received.
- if there is merit in the report, the GC will start a formal investigation and update the log.
- if there is no merit, the GC will classify the report as closed and update the log.
- GC must take all reasonable steps to ensure that investigations regarding the report are fair and impartial.
- GC will keep detailed records of all evidence gathered, interviews conducted, and all records received which may affect the outcome of the investigation.
- GC may be asked to provide further clarifications and information from time to time in the course of the investigation.
- GC may call any Employee as a witness to facilitate the investigation.
- GC may share the information regarding the report with others (internal and external parties) on a “need to know” basis to facilitate the investigation.
- If any of the GC members or CEO is the suspect involved in the Improper Conduct, such member will be automatically abstained from performing any activities relating to the report received from the Whistleblower including but not limited to attending meetings or involved in the investigation
- GC will complete the investigation report and present to BAC the GC’s recommendations for implementation of corrective or preventive actions
- BAC to consider the recommendation and provide feedback or directions to Chief Executive Officer, Chief Operation Officer and Human Resource based on the proposed corrective or preventive actions
- GC will contact the Whistleblower (if the identity is disclosed) within 60 working days of receiving the report or until the conclusion of the investigation, explaining what actions that have been taken by MHTC.
- Training on this Policy forms part of the induction process for all MHTC’s new and existing Employees.