Code of Ethics and Professional Conduct

At HealthCare Innovation (HCI), ethics is not an accessory — it is the foundation of our identity as a national and Euro-Mediterranean HealthTech cluster.

Operating at the intersection of public health, innovation, and private enterprise, we uphold the highest level of professional conduct, scientific integrity, and transparency.

Our Code of Ethics applies to all:

• Staff members
  
• Board and Executive Committee
  
• Experts, evaluators, and mentors
  
• Startups and founders
  
• Contractors, suppliers, and partners
  
• Participants in HCI programs, events, and initiatives
  

1. Our Ethical Commitment

HCI’s ethical principles are informed by:

• The Bogotá Principles (Ethical Business Practices in the Medical Device Sector)
  
• The Tunisian Code of Medical Deontology
  
• International norms related to research integrity, data ethics, responsible innovation, and clinical safety
  
• EU and WHO guidelines on digital health and health technologies
  
• HCI’s own Safeguarding, PSEAH, and ESG policies 

We commit to acting with transparency, integrity, fairness, inclusion, and accountability in all operations and partnerships.

2. Patient & Public Interest First

As a cluster serving the healthcare ecosystem, we affirm that:

• Patient safety takes precedence over commercial gain 
• Any innovation supported by HCI must follow ethical, clinical, and regulatory standards
  
• Solutions presented by startups must not mislead, overpromise, or endanger users
  
• Clinical, scientific, or performance data must be accurate, traceable, and ethically obtained
  

Startups or partners engaging in:

• data manipulation,
  
• falsification of clinical or regulatory documents,
  
• plagiarism,
  
• misleading clinical claims,
  will face immediate expulsion from the cluster and potential notification to relevant authorities. 

3. Conflict of Interest (COI)

3.1 Definition

A conflict of interest occurs when personal, financial, or professional interests may influence — or appear to influence — one’s judgment, decisions, or responsibilities within HCI.

Conflicts can be:

• Actual
  
• Potential
  
• Perceived
  

3.2 Mandatory Annual Declaration

All HCI Board members, staff, evaluators, and experts must complete an Annual Declaration of Interests, outlining any relationships that may interfere with impartiality, including:

• Financial holdings
  
• Advisory roles
  
• Investment interests
  
• Employment or consulting with med-tech or health startups
  
• Family or close personal ties with cluster members
  
• Prior or ongoing collaborations
  

3.3 COI Disclosure During Activities

During selection committees, evaluations, accelerators, grant reviews, or procurement processes:

• Any person with a conflict must declare it immediately
  
• They must recuse themselves from discussions, scoring, and voting
  
• Recusals are recorded in official minutes
  

Non-disclosure of a conflict of interest is considered misconduct.

4. Scientific & Research Integrity

HCI upholds the highest standards of scientific and academic integrity.

4.1 Zero Tolerance for Scientific Misconduct

The following actions are prohibited and lead to disciplinary actions, including potential expulsion:

• Fabrication (inventing data or results)
  
• Falsification (manipulating research methods, images, outcomes)
  
• Plagiarism (copying ideas, algorithms, designs, text, or scientific work without proper attribution)
  
• Selective reporting or suppression of negative results
  
• Misleading marketing claims about performance, accuracy, or safety 

4.2 Clinical & Regulatory Accuracy

Startups collaborating with HCI must:

• Follow ethical clinical research practices
  
• Respect the MDR (EU), Tunisian regulations, and WHO recommendations
  
• Ensure transparency about clinical validation status
  
• Avoid unverified medical claims, especially for AI-based or diagnostic solutions
  

5. Professional Conduct & Values

5.1 Respect & Dignity

All HCI representatives must treat colleagues, founders, researchers, health professionals, and partners with respect, professionalism, and cultural sensitivity.

5.2 Integrity in Communication

We commit to:

• Clear, honest communication
  
• Avoiding exaggeration or unverified promises
  
• Transparent representation of startup capabilities and program outcomes
  

5.3 Protection from Abuse & Harassment

HCI enforces:

• Zero tolerance for harassment, abuse, discrimination, or misconduct
  
• Strict compliance with our PSEAH policy and Tunisian Law 2017-58 

Unethical behavior of any kind warrants disciplinary action.

6. Ethical Collaboration With Partners

HCI ensures that partnerships — national or international — are governed by ethical principles.

Partners, suppliers, and contractors must commit to:

• Avoiding corruption, bribery, or undue influence
  
• Transparent procurement and reporting
  
• Ethical clinical and scientific practices
  
• Compliance with data protection and confidentiality requirements
  

Partnership agreements include ethics clauses, disclosure expectations, and safeguards.

7. Responsibilities of Startups & Members

Cluster members must:

• Adhere to this Code of Ethics
  
• Follow sector regulations, including MDR (EU), Tunisian data protection, and deontology guidelines
  
• Protect patient data and confidentiality
  
• Maintain professional integrity during events, hackathons, and cocreation activities
  
• Avoid conflicts of interest in competitions or fundraising processes
  

Startups violating these provisions may lose access to cluster support, programs, funding opportunities, and visibility.

8. Reporting Misconduct

HCI encourages a Speak-Up Culture.

Anyone can report ethical concerns, misconduct, conflicts of interest, or scientific fraud.

HCI guarantees:

• Confidential handling of concerns
  
• Protection from retaliation
  
• Fair investigations
  
• Proportional corrective action
  

9. Enforcement & Disciplinary Measures

Depending on severity, actions may include:

• Written warning
  
• Mandatory training
  
• Removal from committees
  
• Suspension of cluster membership
  
• Expulsion from HCI
  
• Notification of regulatory authorities or institutional partners
  

10. Review & Continuous Improvement

The Code of Ethics is reviewed annually by HCI’s Board and Ethics Committee.

Updates incorporate:

• New Tunisian regulations
  
• International standards (WHO, OECD, EU, Bogotá Principles)
  

Evolving best practices in digital health and MedTech ethics