Anti-Corruption Policy

The management of LyVes Clinic enforces a policy of absolute zero tolerance for any forms of corruption, fraud, and conflicts of interest. This Anti-Corruption Policy is aimed at building a transparent, ethical, and responsible environment for providing medical services, as well as protecting the trust of our patients, partners, and society.

I. Objectives and Basic Principles

The main objectives of these internal rules are:

• Ensuring transparency, enhanced control, and accountability in the management of the medical facility’s resources.
• Improving effectiveness in preventing corrupt practices and minimizing corruption risk.
• Creating secure internal mechanisms for receiving and objectively reviewing complaints and alerts from patients and employees.

In its operations, LyVes Clinic is guided by the principles of the rule of law, fair competition, high professional morality, and strict compliance with the ethical rules of conduct by the entire team.

II. Preventive Measures and Unacceptable Actions

In order to limit corruption risk, the Clinic’s management applies strict preventive measures (including the introduction of electronic administrative services for transparency) and strictly prohibits:

• Requesting and accepting unregulated payments: Employees are not allowed to request, accept, or promise material or non-material benefits (gifts, money, services) in order to perform or not perform an official action.
• Abuse of official position: Using one’s position to extract personal benefit or to benefit family and related persons is absolutely unacceptable.
• Undue influence: Exerting pressure on colleagues, patients, or partners to achieve personal or third-party financial goals.

III. Conflict of Interest

To guarantee the impartiality of medical and managerial decisions, every employee of LyVes Clinic is obliged to observe the following rules:

• An employee may not participate in discussing, preparing, or making decisions when they or related persons have a private interest that raises reasonable doubts about their objectivity.
• If a doubt or an actual conflict of interest arises regarding an assigned official task, the employee is obliged to immediately notify their direct supervisor.
• Employees do not participate in any transactions that are incompatible with their position, functions, and duties at the Clinic.

IV. Professional Conduct

Every employee of LyVes Clinic carries out their activities competently, objectively, and in good faith, in compliance with the laws of the Republic of Bulgaria and internal regulations. Discriminatory attitudes, offensive qualifications, or creating conflict situations among employees or with patients are not allowed. Management personnel are obliged to set a personal example of responsible and ethical behavior.

V. Submitting and Reviewing Alerts

LyVes Clinic encourages any patient, employee, or partner who has information about a corrupt act, conflict of interest, or unethical behavior to submit an alert.

• Alerts can be submitted through the Clinic’s official communication channels. Anonymous alerts are not considered unless they contain specific and verifiable facts about significant violations.
• Management guarantees strict confidentiality and full protection of the identity of persons who submit an alert in good faith.
• Every alert is thoroughly investigated. If evidence of a crime is established, the Clinic Manager immediately notifies the competent authorities (the Ministry of Interior or the Prosecutor’s Office of the Republic of Bulgaria).

VI. Control and Responsibility

Compliance with the Anti-Corruption Policy is mandatory for all LyVes Clinic personnel, regardless of their position. Violations of these rules lead to serious disciplinary measures and the bearing of corresponding financial and/or criminal responsibility according to the law.