Code of conduct

Correct ethical behavior, sincerity, reliability and integrity are guiding principles within Lassus, internally, to clients and externally.

It is imperative that each of us protect the good name of Lassus. This requires a culture that has a strong commitment to openness, integrity and ethical behavior. Whatever our role within the company, we are all responsible for upholding our ethical and legal principles.

We have adopted this Code of Conduct (the Code) established to explain these principles to everyone working at, for or on behalf of Lassus, regardless of the legal relationship (the Medewerkers). Op hen is de Code expliciet van toepassing.

In this context,  Lassus means Holding Lassus Tandartsen B.V. and all companies affiliated with this company, which expressly includes (but is not limited to) Lassus Facilitair B.V., Lassus Tandartsen B.V., Lassus Tandartsen Keizersgracht B.V., Tandartspraktijk De Liefde B.V, Tandartspraktijk Plantage Middenlaan B.V., Lassus Tandartsen Olympisch Stadion B.V., Dental Factory B.V., TTH Van Wou B.V., Lassus Orthodontie B.V., Lassus Tandartsen Lelystad B.V., Oisterwijk Tandheelkunde B.V., Dentista Amsterdam B.V. and all companies in which the various branches of Lassus are incorporated.

The Code is divided into sixteen topics relevant to Lassus’ business activities. The Code provides clear principles regarding integrity and ethics in doing business.

The Code governs our decisions and actions and applies to both business actions and the conduct of Employees while working for Lassus. In addition, the Code is instrumental in the decision to enter into or continue relationships with clients, suppliers and other third parties.

The Code covers the minimum conduct requirements and is not exhaustive.

2. Culture within Lassus

Lassus is like a three-star restaurant that approaches every customer the same in terms of service. Whether the customer dines elaborately or modestly, chooses expensive or cheaper wines, does not make him more or less welcome. In either case, he can count on a perfect meal and the best service. Because only then does the establishment retain its stars and the customer comes back.

Service is another name for service. Service to satisfy customers / clients, either by offering goods or services they request in exchange for money, or by solving problems or taking up complaints. If complaints are handled properly and problems are solved within a short period of time, we speak of good service. And because good service contributes to customer satisfaction which in turn creates more revenue, the company’s turnover increases and investments for expansion or improvement can be made.

In order to achieve high client satisfaction and client loyalty, Lassus uses the values below as basic values for its culture:

• Open up to people’s needs before they ask for them themselves;
• Help each other (teamwork);
• Accept the feelings of others (empathy);
• Respect the dignity and privacy of your fellow man (courtesy); and
• Explain what is going on (communication).

3. Legislation

Lassus is committed to compliance with all relevant laws and regulations and also expects this of all its Employees. This includes all laws and regulations, regardless of the country where the work or activities take place or where a Lassus affiliate is located. Care specific or general.

Care specific relevant laws and regulations include at least:

1. Medical Treatment Agreement Act (WGBO).
2. Personal Data Protection Act
3. Individual Health Care Professions Act (BIG).
4. Healthcare Facilities Quality Act
5. Client Care Sector Complaint Act
6. Occupational Health and Safety Act
7. WIP guideline
8. Radiation Protection Decree
9. Nuclear Energy Law
10. Medicines Act

General relevant laws and regulations in the Netherlands include at least:

1. official bribery                     (Article 177 Penal Code(CPC))
2. forgery                     (Article 225 WvS)
3. theft                                              (Article 310 WvS)
4. extortion                                          (Article 317 WvS)
5. blackout                                   (Article 321 WvS)
6. embezzlement in office                      (article 322 WvS)
7. scam                                         (article 326 WvS)
8. non-official bribery               (article 328ter WvS)
9. money laundering                                        (Article 420aa WvS)
10. Insider trading or other acts in violation of the Financial Supervision Act and related laws and regulations

4. Competition

Lassus does not shy away from competition, as long as competition takes place in a fair manner. Lassus supports the development of appropriate competition laws. Lassus’ companies and Employees conduct their operations in accordance with all principles of fair competition and all relevant laws and regulations.

5. Confidential information and protection of personal data

Employees must treat all company information as confidential and may not disclose company or client information to third parties without the express permission of their immediate supervisor and the client. Express reference is also made at this point to confidentiality obligations imposed in other documents, such as the employment contract. Employees are required to respect and protect company information, including information on computers and other equipment, and may not disclose company information even after termination of their employment.

Lassus and its Employees protect the privacy and security of the personal data of clients, Employees, suppliers, and any other party with whom they do business. Personal data may be used only for legitimate business purposes and in accordance with legal requirements. Employees who suspect a breach of Lassus’ data security should report it immediately.

6. Conflict of interest

All Employees are expected to perform their work in the best interests of Lassus. They must avoid any conflict of interest, including conduct that strictly speaking does not involve a conflict of interest but may give the appearance of one, between the interests of Lassus and personal interests.

In particular, it is prohibited to conduct business transactions between Lassus and clients and/or suppliers, in which the Employee or one of his or her family members has a financial or managerial interest, unless expressly agreed upon and approved by management. Any possible case of conflict of interest should be reported to the immediate supervisor of the Employee concerned. If in doubt, the Employee should consult with his or her immediate supervisor.

7. Receiving and offering gifts and entertainment

As a rule of thumb, Employees are not permitted to accept gifts or entertainment from or offer them to clients, suppliers, and others with whom Lassus has a business relationship and whose value exceeds what can be considered common courtesy (a maximum of €50).

It is never permitted to accept or offer cash unless the Employee has express permission from management.

8. Business assets and equipment

Each Employee is responsible for the proper use, protection and preservation of Lassus assets and resources and confidential information provided to us by our clients and business partners. This includes the property, assets, property interests, financial data, trade secrets, information and other rights of Lassus.

Assets and resources of Lassus and opportunities for Lassus should be used in pursuit of the goals of Lassus and not for personal gain. Employees who suspect they are dealing with conflicts of interest should take the matter up with their immediate supervisor.

9. Integrity of registrations

Lassus’ corporate records are the basis of our reliable and accurate reporting to management, regulators, the Health Care Inspectorate, shareholders, creditors, government agencies and other parties. All official records of Lassus must therefore be accurate, honest and complete. Lassus does not permit payments to be concealed by routing them through the accounts of third parties, such as intermediaries or consultants. All Lassus business activities must comply with all local and national laws and regulations regarding the accurate and complete maintenance of financial records.

10. Bribery and corruption

Lassus relies on its own strengths and competes fairly based on its services and service delivery. Lassus believes this sets it apart in the marketplace.

Any form of bribery is unacceptable to Lassus. Personal payments to or bribery of persons employed by clients or suppliers of Lassus, government officials or legislators, or bribery of or personal interests to Employees of Lassus, are strictly prohibited.

11. Contribution to political parties and insider trading

As a rule of thumb, no money or resources may be used to support political candidates or parties anywhere in the world. Lassus does not support political parties or donate money to groups dedicated to promoting party interests. Lassus prohibits the use of Lassus facilities or resources by Employees for political campaigning, political fundraising or partisan political purposes.

Although Lassus is not a publicly traded company, Lassus or its subsidiaries may participate or consider participating in business transactions with publicly traded companies. Employees who have knowledge of (potential) business transactions with a publicly traded company may not engage in trading in shares, options or other securities of the company in question until such transactions are public knowledge.

12. Employee Relations

Lassus is committed to equal opportunity and a respectful work environment. Employees are not permitted to discriminate on the basis of race, religion, sex, national origin or any other status prohibited by law. Sexual harassment will not be tolerated.

13. Alcohol and drugs

At Lassus, the use of alcohol and/or drugs is not permitted on the premises, in the office or on the shop floor. Employees will be denied access and/or removed from their offices or the workplace if they are under the influence of alcohol and/or drugs.

14. Communication with third parties

Only duly authorized Employees are permitted to speak to inspection, creditors, media, suppliers and other third parties on behalf of Lassus. Employees authorized to speak or act on behalf of Lassus must abide by the limitations of such authority and may not attempt to exceed or circumvent it.

15. Violations

Violations of the Code may result in disciplinary action against the affected Employee. Lassus reserves the right to address such violations as it deems appropriate under the circumstances. This does not exclude the possibility of summary dismissal and immediate termination of a contract of assignment or cooperation agreement.

16. Report inappropriate, unethical or unlawful conduct

Lassus is committed to a culture based on trust and individual responsibility. However, Employees may encounter unethical or unlawful behavior in the course of their work. Lassus is committed to providing an environment in which Employees can raise any concerns about wrongdoing. We want to provide a safe and fair way to report such behavior in good faith. It is the duty of each Employee to report such violations. This report may be made, anonymously or otherwise, to the HR Department or management.

17. Other guidelines

This document addresses the main aspects of ethical behavior that Lassus expects of its Employees. The Code cannot anticipate every possible legal or ethical issue that may arise and therefore may not be specific enough on certain topics. Employees who have questions about the Code or need guidance in certain situations should contact their immediate supervisor, who will then address the issue as seriously as possible. In addition, they may contact the HR department or Lassus management for advice or guidance.