Report - COP Prototype

2022 Communication on Progress

Manila Doctors Hospital

Published date

May 27, 2022

No. of questions

Supplemental files

Social Vision.pdf DEW-P-001, A PP on General Waste Management.pdf MDH Blue Book.pdf Scan12.jpg

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

Optional comment

Regular risk assessment is conducted and matters concerning environment is being monitored and reported by the hospital ENVICOM (Environment Committee) in collaboration with the Corporate Responsibility Office, undertakings in connection with human development concerns are being implemented and monitored by the CSRO, a unit that is integrated under Governance.

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

We are the only private hospital in the Philippines that has openly committed to a Social Vision

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

It is contained in a controlled documents.

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

Optional comment

This also includes a Whistleblower policy

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	14
Male (%)	71
Female (%)	29
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	0
Above 50 years old (%)	100
From minority or vulnerable groups (%)	0
Executive (%)	14
Independent (%)	14

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

we are regularly audited by the Department of Labor and Employment, Department of Environment and Natural Resources, Department of Health and

Other (Please provide additional information)

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
2009 for the blue book, 2010 for the medical and dental consultant staff and 2021 for the collective bargaining agreement for its employees association.
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

This is included in our Blue book (Overall company policy) or the revised code of employees' conduct and discipline while the hospital has a specific red book or the consultants manual for its doctors and dentists. The hospital also has the white book or the collective bargaining agreement for the employees association.

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing /mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
zero tolerance policy and should there be any possible case the multi-stakeholder Ethics Committee reviews the case and has a timeframe in issuing recommendation which is acted upon by the top management and if need be the board, depending on the position of the subject (person)
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

The governance system of the hospital will be broken down further to be integrated in the daily operations of the hospital. This includes deepening the awareness of the whole internal community on their basic rights including the benefits and protection being accorded to them by the organization.

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
2021
Forced labour
2009
Child labour
2009
Non-discrimination in respect of employment and occupation
2009
Occupational safety and health
2009
Working conditions (wages, working hours)
2021

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	100

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)	89

Optional comment

Confidential employees although benefitting from the collective bargaining agreement are not members of the union given the confidential nature of their work. This is supported by the Labor Code of the Philippines.

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	69
Non-executive board	31

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)	100

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	0.1

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate	0.1

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

Manila Doctors Hospital recently (2021) has successfully signed a 5 year collective bargaining agreements with its employee union.

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2010
Water
2019
Oceans
Forests / Biodiversity / Land Use
Air Pollution
2019
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2021
Energy & Resource Use
2019

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
In partnership with Earth Island
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

We are working with external partners who are experts in the field

4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

	Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Climate Action	Recycling of water. Already being done is the reverse osmosis filter back-wash wherein the water coming from the hemodialysis machine is filtered through the reverse osmosis machine. It can produce 10,000 liters of backwash water in day. The class B water produced after this process is then used for cleaning, the hospital vicinity, lavatories and watering the plants. The water is safe and guaranteed not to cause any infection.. For the next two years MDH is planning to produce and use more recycled water.
Energy & Resource Use
Water
Forests / Biodiversity / Land Use	Increase the number of clean and green spaces that the hospital will adopt. At the moment the 2.2 hectare Arroceros Forest Park or what is commonly known as the last lung of Manila is included in the GREEN (Generating Resources & Engagement for Environment & Nature) Rebellion. Arroceros Forest park is owned by the City of Manila but is under constant threat because of its strategic location in terms of possible business opportunities. Data shows that there are 1,567 trees: 217 species are endangered, 12 are endemic (can only be found in the Philippines), 16 are currently classified as threatened, 22 are exotic/introduced species and 47 are native species (can only be found in Southeast Asia). The tree inventory was done by the University of the Philippines, Los Banos College of Forestry and Natural Resources, the Department of Forest and Biological Sciences. The parameters of the inventory included all types species, except those that are less than 10 centimeters in diameter. The Wild Bird Club of the Philippines documented at least 27 bird species - both resident and migratory - inside the park, such as Zebra Dove, Whiskered Tern, Coppersmith Barbeth, Brown Shrike, etc. Butterflies and fireflies can also be found inside Arroceros. Although an ordinance was promulgated, the current outgoing Mayor of Manila commissioned a landscape turning the forest park into a pseudo amusement park which destroyed the protected biodiversity of the last lung of Manila. The goal is to reclaim the biodiversity not just for environmental reason but for the health benefits that Arroceros used to afford the residents of the 5th district of Manila.
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

7789

Scope 2 Emissions

Full

None

not applicable

Emissions (tCO2e)

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

Optional comment

fuel and energy related activities. Waste generated in operations

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

focusing on accrediting suppliers who are producing products with low carbon footprint but the supply chain during the pandemic forced the hospital to set-aside some of its standards specifically in sourcing PPEs.

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

Unknown

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

mostly from food supplies

Unknown

Not applicable (Please provide additional information)

Sector-specific: Water

12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

Water withdrawal (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	766138.73
Groundwater:
not safe due to flooding
Surface water:
operates in a highly urbanized area
Rainwater:
no system and rainwater in the area is highly acidic. not applicable for medical setting.
Wastewater:	18000
Percentage of water withdrawn in regions with high or extremely high water stress (%)

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	766138.73
Groundwater:
same reason as above
Surface water:
same reason as above
Rainwater:
same reason as above
Wastewater:	18000
Percentage of water consumed in regions with high or extremely high water stress (%)
same reason as above

Optional comment

The system that we were putting in place was disrupted due to the pandemic but we plan to continue this year.

13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

Water intensity of products (cubic meter/$):

Unknown

Not applicable (Please provide additional information)

more of consumer but is able to recycle water

Sector-specific: Waste

18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

Waste Generated (t)

250

Unknown

Not applicable (Please provide additional information)

19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

Hazardous Waste Ratio (%)

Unknown

Not applicable (Please provide additional information)

20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

Single-use plastics (tonnes)

Unknown

Not applicable (Please provide additional information)

Miniscule amount of single use plastic waste. Our campaign to ban single use plastic started 16 years ago along with Polystyrene foam. The hospital is using bio-compostable packaging and reusable tumblers.

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

Strengthening of #ZeroWasteAction internal campaign in pursuit of circular economy. Direct transactions with MSMEs specifically for the supplies of our dietary department. Utilization of metal furrings in all construction to avoid using fresh wood in support of the campaign against deforestation.

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

2014

Optional comment

MDH took a closer look at our Ethics policy after our membership with the UNGC was accepted by the New York Headquarters.

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

Includes in the Manila Doctors Hospital Revised Code of Employees' Conduct and Discipline which we have uploaded here in the Labour section of questionnaires.

Prevention

3. Who receives training on anti-corruption and integrity?

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

Optional comment

This is included in our Continual Improvement Program (CIP) and QM (Quality Management) Hour

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	0
n/a
Confirmed during the current year, and related to this year	0
n/a

Optional comment

This is according to both our Internal Audit and Quality Safety and Risk Management Office.

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

Optional comment

Annual review and audit of all units/ departments and directory is conducted every year.

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

It is embedded in our corprate governance system

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

1. Review of Governance Manual 2. Updating of the MDH Ethical framework 3. Updated whistleblower policy 4. Collaborative audit between Quality Safety Risk and Management Office and the Internal Audit