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Ethics Policy & Code of Conduct for Suppliers

Paragon Health was established to help meet the demands for Personal Protective Equipment (PPE) and to provide a stable and safe local supply of surgical masks. We operate in many markets worldwide and we pride ourselves on our reputation for acting fairly and ethically wherever we do business. Our reputation is built on our values as a company, the values of our employees and our collective commitment to acting with integrity throughout our organisation.


Paragon Health condemns corruption in all its forms and we will not tolerate it in our business or in those we do business with. From the confines of our working environments, it is sometimes difficult to grasp the scale of the damage that bribery does to societies. It is not a victimless crime; far from it:


"Corruption … undermines democracy and the rule of law, leads to violations of human rights, distorts markets, erodes the quality of life and allows organised crime, terrorism and other threats to human security to flourish. This evil phenomenon is found in all countries - big and small, rich and poor…corruption hurts the poor disproportionately by diverting funds intended for development, undermining a government's ability to provide basic services, feeding inequality and injustice and discouraging foreign aid and investment. Corruption is a key element in economic under-performance and a major obstacle to poverty alleviation and development." (Kofi Annan, former UN Secretary General)


Our Code of Conduct sets out in detail how you should behave and what you should do if you are confronted with corruption. The Company expects that all of you, our colleagues and all those we work with, will embrace the Code and its values and use them in all aspects of your day-to-day work.


If you have any doubts about anything at all, refer to the Code of Conduct or you can speak to your manager or a director in complete confidence. We will stand by you in acting ethically.

Remember, take the RIGHT approach, and we can eradicate corruption together:

  • You are responsible for your actions. If you break the law, you will have to face the consequences - which could mean a fine, imprisonment, or both.

  • Don't compromise your integrity. If you think something is wrong, ALWAYS report it. If you aren't sure, consult the Code of Conduct. Don't ever let yourself be forced into doing something you know or suspect is wrong.

  • Always pay genuine prices for genuine goods and services. Never pay over the odds. Agents who ask for especially large fees or commissions may do so in order to pay bribes on your

  • Updated June 2021


  • If this happens, you will be responsible. Excessive payments are obvious and will always be uncovered.

  • Act honestly and in good faith at all times and in all aspects of your work.

  • Keep accurate records (including all invoices and receipts) of everything that you do, especially in relation to the payments you make and what they are for. Full and accurate records demonstrate complete transparency and that you have nothing to hide.


Don't bribe. Do the RIGHT thing.


Our policy requires all suppliers and sub-contractors to comply with our Labour Standards Policy, in particular our policies on freedom of association, collective bargaining, discrimination, child labour, working hours, working conditions, forced and compulsory labour, human rights, equal pay, wages and benefits and reporting grievances.

Who We Work With


Group Purchasing Organisations

MedSurg Distributors

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