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Delta Medical Integrity Line — Reporter’s Guide

What can you report?

You can submit a report about known actual or probable violations relating to the following matters:

  • conflict of interest;
  • gifts and hospitality;
  • corruption and fraud;
  • forgery or destruction of information;
  • espionage and sabotage;
  • abuse of official position or of trust in contractual relations;
  • discrimination, harassment, bullying, sexism;
  • sexual or other harassment;
  • moral or psychological pressure, manipulation, revenge;
  • abuse of the work schedule;
  • unfair dismissal;
  • ignoring reports, delaying the review of applications, creating barriers to communication;
  • revenge and persecution of the reporter;
  • other actions that create an atmosphere of bias, injustice, etc.;
  • environmental protection, people’s health and safety
  • threats and physical violence;
  • improper keeping of accounting records, conducting audits, or distortion of any other material reporting;
  • fabrication and falsification;
  • circumvention of internal controls;
  • official negligence;
  • disclosure of confidential information and trade secrets;
  • violation of tender procedures;
  • improper performance of obligations under concluded contracts;
  • antimonopoly legislation or unfair business practices;
  • violation of the Company’s policies.

How to report?

You can report in one of three ways convenient for you:

Please note that the Integrity Line does not register a report if:

  • it does not relate to the activities of Delta Medical, its employees, or processes related to partner interaction;
  • it contains only general value judgments without specific facts that cannot be verified;
  • it is a repeat report on an issue that has already been reviewed and closed, and on which an official conclusion has been provided;
  • it contains complaints about the actions of third parties who are not employees, counterparties, or partners of the Company;
  • it contains threats against other persons;
  • it concerns domestic, personal, or private conflicts that are beyond the competence of Delta Medical;
  • it relates solely to proposals, ideas, or initiatives for improving, optimizing, or changing business processes that do not contain signs of a violation of legislation, internal policies, or ethical standards of Delta Medical.

Reporting is anonymous!

To guarantee complete anonymity and impartiality in registering reports, the Company has entered into an agreement with an external independent service provider — Ethicontrol LLC.

The provider’s task is to organize the independent registration of calls and reports through an anonymous web portal, as well as to protect the anonymity of whistleblowers. If you do not want to reveal yourself, no one will do so without your consent. The information you provide is confidential within the limits permitted by applicable law.

What happens after your report is registered?

  • You will receive a secret feedback code, with which you can later check the status of the response to your report.
  • The external contractor registers your report and sends it to authorized persons at Delta Medical for initial analysis.
  • The initial analysis involves assessing your information for sufficiency, prioritization, and forwarding it to the responsible persons to resolve this issue.
  • During the analysis, if information is insufficient, the review of your issue may be suspended until you answer additional questions through the Feedback Web Center.
  • Each report is assigned a responsible person and a team that investigates the incident and must resolve your issue.
  • The team of responsible persons contacts you within 30 days from the date the report is registered, informs you of the status of your report, and requests and receives additional information about the results of the investigation and the response measures.
  • Through the Feedback Web Center you can communicate anonymously with the team of responsible persons and share additional files if necessary. In the web center settings, you can change your access details and add or change contact information. If you wish, you can leave an email address to receive automatic notifications about changes in the processing status of your report or the receipt of comments from the Company.
  • After the review of your report is completed, you can rate and provide comments on the work of the responsible persons and the response measures through the Feedback Web Center.

Principles of the Integrity Line:

  • Delta Medical guarantees confidentiality to persons who have reported facts of fraud and corruption.
  • Reports are registered by an independent third party.
  • All 100% of reports are subject to registration, provided they contain the minimum information necessary for the next steps.
  • The verification of the received information is carried out for each report received.
  • The received information is reviewed exclusively by persons who are not participants in this process, which allows them to objectively and independently organize the verification process and draw conclusions regarding the established facts.
  • If the received information is confirmed, the materials will be forwarded to the Company’s top management for taking urgent measures.
  • The taking of specific actions always depends on the nature and severity of the violation.
  • Any terminology used above is interpreted in the same way as defined in the legislation of Ukraine.

Quick Start

  1. Take care of your safety

    • Make sure no one is watching you
    • Do not access the site from a work computer or network
    • Check for encryption (https)
    • Do not include details in your report that could help identify you

  2. Go to the whistleblowers’ portal

    Click “Create a new report” or submit a report by email or phone.

    You can also check the status of your report through this portal.

  3. Select the country in which the event occurred

    Select the country where the event you are reporting occurred.

    Indicate the place of the event, not your country of residence.

    If the situation concerns several countries, select the main one and specify the rest in the description.

  4. Describe the problem

    Please provide a detailed description of the problem. Include as much information as possible and answer the following key questions:

    • What happened?
    • Who was involved?
    • Why did it happen?
    • When did it happen?
    • How did it happen?

    Additionally, you can attach relevant files that will help the response team.

  5. Protect access with a password

    You can set a password to access your report. This will provide additional protection.

    Remember that you will lose access if you forget the password.

    Do not share the password with anyone.

  6. Save the security code

    You can use the security code to check the processing status of your report through the platform or by phone.

    Remember that you will lose access if you forget the security code.

    Do not share the security code with anyone, as anyone could act on your behalf.

  7. Do not forget to check the status of your report

    You are also responsible for the outcome of the investigation.

    Please log in to the Feedback Center to check the status of your report, communicate with the response team, answer their questions, and upload files.

    After the investigation is completed, you will be able to rate the quality of the response received.