Code of Conduct

Introduction

At HealthAI, we believe that how we conduct ourselves is just as important as the work we do. Ethical behavior, both within our organization and in our interactions with external partners, is essential for building trust and credibility—key components in our mission to effectively regulate AI in health.

We are committed to fostering a work environment where every individual is respected and valued. The aim of this Code of Conduct is to provide guidance and to outline the standards of behavior expected from everyone associated with HealthAI.

This Code of Conduct is only one of a broader set of internal HealthAI’s documents and policies (e.g. Fraud and corruption prevention Policy; Procurement Policy; Information security Policies; and the most recent Generative AI Policy). As such, it is not intended as a replacement to any of them, but rather as a complement.

Scope

This Code of Conduct applies to all permanent and short-term, full-time and part-time employees, interns, consultants, contractors and Board Members of HealthAI, regardless of whether they are based at the Headquarters or elsewhere, and regardless of whether they are hired directly by HealthAI or through an Employer of Record or hosted by a partner organization.

In addition, this Code of Conduct applies to any individuals working for or representing the organization at the workplace, at external events, or within online interactions.

As such, this Code of Conduct is to be abided by at all times and in all situations in which any individuals act in the name of HealthAI.

Mission Statement and Core Values

HealthAI advances the development and adoption of Responsible AI solutions in health through the collaborative implementation of regulatory mechanisms and global standards.

To achieve our mission, we strive to create a workplace where everyone can thrive and contribute their best. That’s why we commit to embracing and living by the following Core Values:

• Trust
• Respect
• Integrity
• Dedication
• Accountability

Together, these values guide us in our work and shape our culture, helping us make a meaningful contribution at both individual and organizational level.

Our Values in Action

Trust

Trust is the foundation of our relationships and interactions at HealthAI. It means believing in the ability and reliability of our colleagues and partners. To build trust, we foster an environment where open communication and transparency are prioritized, allowing everyone to feel safe and valued. We believe that by being honest and keeping our commitments, we build strong connections that enable collaboration and innovation. Trust empowers us to work together effectively, knowing that we can depend on one another to support our shared mission.

Examples of expected behaviors:

• We actively listen to others’ perspectives without judgment and encourage a culture where all team members feel comfortable voicing concerns or sharing new ideas.
• We share information honestly and proactively, keeping our colleagues informed about relevant developments and challenges.
• We actively engage with team members, offering assistance and encouragement to help everyone succeed.
• We say what we do, and we do what we say.

Examples of unacceptable behaviors:

• Withholding relevant information, providing false information, or misrepresenting facts, which undermines trust and damages relationships.
• Deliberately excluding colleagues from assignments or conversations that they are responsible for and should be looped into.
• Making exaggerated promises to secure approval or recognition and failing to deliver on them, which creates false expectations and damages trust.
• Publicly sharing confidential or personal information about third parties.
• Disregarding claims of harassment or misconduct.

Respect

Respect at HealthAI means recognizing and embracing the inherent worth and dignity of every individual, both within and beyond our organization. It involves valuing diversity and diverse perspectives, experiences, and backgrounds, and treating everyone with courtesy and kindness. By showing respect, we aim at encouraging open dialogue and at promoting a culture where everyone feels empowered to contribute.

Examples of expected behaviors:

• We respect the efforts made by team members who have specific challenges imposed by their differences.
• We act in a fair and equitable manner towards all our colleagues and stakeholders.
• We give full attention to others when they speak and let them articulate their ideas and concerns without interrupting.
• We engage in discussions respectfully, even when disagreeing, by focusing on ideas rather than on personal considerations or attacks.
• We offer feedback in a supportive and constructive manner, encouraging growth and improvement while maintaining a positive atmosphere.
• We recognize that everyone’s time is valuable, and we show respect by acknowledging messages, emails, and requests for inputs and feedback within reasonable time frames.

Examples of unacceptable behaviors:

• Disregarding or belittling challenges and barriers faced by others in their efforts to contribute.
• Using offensive or disrespectful language, including insults, inappropriate jokes, or derogatory remarks.
• Engaging in any form of harassment or bullying, whether verbal, physical, or emotional.
• Deliberately ignoring or belittling others’ contributions, creating a hostile or unwelcoming environment.

Integrity

Integrity means acting with honesty and strong moral principles in all aspects of our work at HealthAI. It means upholding high ethical standards, making decisions, and taking action based on what is right, not just what is convenient. It comes down to knowing the rules and always respecting them, even when it’s difficult. We do the right things and do things right; if we are in doubt, we ask.

Examples of expected behaviors:

• We take responsibility for proactively knowing the applicable law and regulations, including HealthAI’s internal policies, and abiding by them at all times.
• We disclose any potential conflict of interest immediately and proactively.
• We conduct all aspects of our work (including offer and provision of services, procurement, staff recruitment, etc.) in an open, fair, and impartial manner.
• We consider the ethical implications of our actions and make choices that align with our values and mission.

Examples of unacceptable behaviors:

• Concealing actual or potential conflicts of interest.
• Using deceitful tactics to achieve personal or professional goals.
• Exploiting one’s position in view of obtaining personal advantages.
• Offering, soliciting, or accepting favors, bribes and/or kickbacks in any form (including gifts, hospitality, and/or other business courtesies of excessive value and/or frequency).

Dedication

Dedication is the commitment to act in the interest of HealthAI and to support it in delivering its mission, as well as to stand by our colleagues and stakeholders. It involves being dedicated to the organization’s goals and values, fostering a sense of unity and teamwork. This commitment strengthens our collective efforts and builds a positive work environment where everyone feels motivated to contribute to our shared success.

Examples of expected behaviors:

• We use our competences and our professional expertise for the benefit of HealthAI.
• We actively promote the organization’s mission and values, both internally and externally, demonstrating pride in our work.
• We respect the privacy of sensitive information and maintain discretion regarding organizational matters.
• We manage HealthAI’s financial and material resources efficiently and effectively.

Examples of unacceptable behaviors:

• Failing to uphold HealthAI’s values, or acting in ways that contradict our mission, particularly when representing HealthAI publicly.
• Engaging in competing activities, whether paid or unpaid.
• Engaging in negative talk or gossip about colleagues, HealthAI, and/or its legal representatives.
• Disclosing confidential or sensitive information outside the organization, during and after employment at HealthAI.

Accountability

Accountability at HealthAI means taking ownership of our decisions, of our actions and of our omissions, and accepting responsibility for their intended and unintended outcomes. It reflects our commitment to transparency and reliability in all situations.

Examples of expected behaviors:

• We follow through on our commitments. If unexpected issues arise, we address them proactively, communicate about them, and set realistic expectations for revised outcomes or deadlines.
• We take pride in producing high quality work to the best of our abilities.
• We celebrate our successes, and we learn from our mistakes.
• We are open to exchange and welcome constructive feedback.
• We set the example.

Examples of unacceptable behaviors:

• Failing to take responsibility for own mistakes, and/or blaming others for them.
• Failing to deliver on commitments without notifying relevant stakeholders in advance.
• Deliberately ignoring feedback or refusing to acknowledge areas for improvement when issues are raised.
• Claiming or taking personal credit for work done within our working relation with and on behalf of HealthAI.
• Withholding or concealing important information that could impact the team or the work.

Additional Standards of Conduct

Personal Conduct when Representing HealthAI

Team members are expected to adhere to this Code of Conduct at all times while on mission and in any setting where they represent HealthAI. Moreover, while HealthAI respects the personal lives of its team members and does not seek to intervene in private matters, certain situations may arise where personal conduct can impact the organization’s reputation. Therefore, team members are reminded that their actions and behavior outside the workplace, even if unrelated to their official duties, may still affect the public image and interests of HealthAI.

Intellectual Property

All work produced by staff members during their employment with HealthAI is the exclusive property of HealthAI. This includes any research, creations, documents, designs, or inventions developed as part of their professional duties. As the employer, HealthAI retains all rights to such work, including copyrights, trademarks, and, where applicable, patent rights. Staff members may not use, reproduce, or distribute this work for personal purposes or represent it as their own without prior written consent from HealthAI.

Reporting and Enforcement

At HealthAI, every individual plays a critical role in upholding our values and maintaining a positive, respectful workplace. Abiding by the Code of Conduct is essential not only for fostering an environment of mutual respect but also for ensuring that everyone feels safe and valued. Therefore, we all have a shared responsibility to support the integrity of this Code, both by our own behavior and by helping to address any actions that fall short of our standards.

Responsibility to Report Misconduct

It is essential that each one of us feels empowered to speak up if we are the victim of or witness to any unacceptable behavior or misconduct. Reporting such behavior is not only a responsibility but also a way to protect the well-being of colleagues and the overall health of the organization.

Escalation Process

Team members are warmly encouraged to address these issues openly and constructively with the person involved whenever possible. This approach can often resolve situations before they become issues, fostering a culture of accountability and open communication.

If addressing the concern directly is not feasible or does not lead to a resolution, team members are encouraged to escalate the matter through the following channels, in order of priority and applicability:

1. Line Manager: the first point of contact should be the employee’s line manager, who can provide guidance and address the concern at an operational level;
2. Chief Operating and People Officer (COPO): if escalation to the line manager is not appropriate or does not resolve the issue, the COPO can be approached to handle the concern from a broader organizational perspective;
3. Chief Executive Officer (CEO): in cases where the report involves the COPO or if it remains unresolved, employees may contact the CEO directly;
4. Chair of the Board: in very exceptional situations, e.g. if the concern involves the CEO, the issue can be escalated to the Chair of the Board; such escalation should be done through or in agreement with a member of the Senior Management Team.

Enforcement and Disciplinary Measures

HealthAI takes violations of the Code of Conduct seriously. Each report will be handled with discretion and investigated appropriately to ensure fair and impartial enforcement of the Code itself. Depending on the severity of the behavior, disciplinary actions may be taken, up to and including immediate dismissal for cases involving serious professional misconduct.

Continuous Improvement

This Code of Conduct will be reviewed annually to ensure its relevance and effectiveness. Any changes will be communicated to all team members through staff meetings and/or email updates as appropriate.

This Code is designed to guide us in our everyday interactions, helping us create a respectful and supportive work environment. However, the true measure of success will reside in how we bring its principles to life in our daily actions. Reality—the way we live and embody these guidelines in our workplace—matters far more than the document itself.

To ensure that this Code is and remains relevant, raising awareness and committing to regular review is essential. Therefore, going forward we will aim at creating real-life opportunities, such as workshops and team sessions, where we can openly discuss the values and expectations outlined here and explore how they play out in practice. This will allow us to ensure that the Code truly reflects our collective values, and that

the behaviors associated with them accurately represent our evolving standards and the way we want to see our values in action.

While each of us is responsible for fostering a respectful, collaborative work environment, the Chief Operating and People Officer (COPO) is the primary steward of this Code of Conduct. This includes ensuring that it remains up-to-date, relevant, and aligned with our shared values.

The Code will undergo reviews by the COPO on an annual basis, and will be updated as necessary to reflect our continuous commitment to improvement. Changes will be submitted to the Board.