Our Commitment
At Medov, we are committed to conducting our activities with honesty and integrity, and we expect anyone working with us to act with the same high standards toward our team, clients, business partners and the wider community.
We encourage our staff and business partners to report suspected wrongdoing as early as possible, with the assurance that concerns will be taken seriously, investigated appropriately, kept confidential and protected from retaliation.
We believe that open and honest communication is the foundation of informed and constructive decision-making. For this reason, we encourage every team member to speak freely whenever they encounter a non-compliance situation, such as harassment, discrimination, abuse of power, bullying, fraud, corruption or conflict of interest. Non-compliance covers all behaviours contrary to our values, our Code of Conduct and the laws and regulations of the countries in which we operate.
If you do not feel comfortable contacting your Line Manager, HR or the Compliance Manager, you can always submit a confidential report through our Whistleblowing system.
Whistleblowing is the disclosure of information regarding suspected wrongdoing or risks at work that have occurred or may occur. This includes—but is not limited to—criminal activities, breaches of legal or regulatory requirements (including EU legislation), corruption, risks involving human rights violations, health and safety risks, environmental damage, violations of Medov’s Code of Conduct or internal policies, and the deliberate concealment of any such issue.
Reports relating to ethical violations may be submitted confidentially or anonymously through our Whistleblowing platform, which includes a secure website and a free telephone service. The platform also contains Medov’s Whistleblowing Policy and privacy notice.
Your support helps us meet our commitment as a responsible business partner.
Reports may be submitted by the following individuals (“Users”), if they become aware of relevant information within their work context:
- Medov employees (permanent, part-time, intermittent, fixed-term, agency, apprenticeship, accessory work)
- Self-employed workers
- Contractors and collaborators
- Freelance and consulting partners
- Volunteers and interns (paid or unpaid)
- Shareholders and individuals with administrative, management, supervisory or representative roles, including de facto roles
Reports may also be made:
- before the work relationship begins (e.g., during selection or pre-contractual phases),
- during probation,
- after the work relationship ends, if the information was obtained during the relationship.
Reports may concern any alleged violation or attempted violation affecting the public interest or the company’s integrity, if learned within the context of the relationship with Medov.
They may involve:
- breaches of national or EU provisions in specific sectors (public procurement, financial services, anti-money laundering, product safety, environmental protection, consumer protection, data protection, cybersecurity, etc.)
- breaches of EU law affecting the Union’s financial interests or undermining the objectives of EU legislation
- breaches of national law (administrative, accounting, civil or criminal), violations under Legislative Decree 231/2001, or breaches of the company’s organisational model
Reports not covered by whistleblowing protections include:
- unsubstantiated rumours
- personal grievances
- employment-related disputes
- conflicts with supervisors or colleagues
Medov’s Whistleblowing channels are available 24/7, 365 days a year.
To ensure confidentiality, the system is managed by an independent external provider.
Reports may be submitted via the following link: Compliance Hotline
Alternatively, confidential letters may be sent to:
Compliance Office – I.L. Investimenti
Via A. Cantore 8G/121 – 16149 Genoa
Third parties working with us are also encouraged to report through our Whistleblowing system.
- Submit your report via the web form, choosing whether to remain anonymous.
- Provide a detailed description (who, what, when, how) and any supporting evidence.
- You will receive a unique case number, used to follow up.
- All reports are assessed, and appropriate measures are taken.
- You may monitor progress using your case number.
- Acknowledgment within five working days.
- Assessment: Reports containing sufficient information trigger an internal investigation.
- Escalation: Serious cases may be referred to Group HR and Legal.
- Confidentiality: Only essential personnel are involved; interviews may be conducted.
- Timeline: Investigations generally require around 90 days.
- Outcome: You will receive updates and a final response. Possible outcomes include:
- Corrective actions
- Disciplinary measures
- Referral to judicial or financial authorities
- Archiving due to insufficient evidence
Medov does not tolerate any form of retaliation or discrimination against whistleblowers.
Under Italian Legislative Decree 24/2023, whistleblowers may report directly to ANAC if:
- the internal report has not been addressed,
- they reasonably believe retaliation may occur, or
- the violation poses an imminent or serious risk to the public interest.
Whistleblowers may lose protection—and face legal or disciplinary consequences—if they submit false, defamatory or malicious reports, or misuse the reporting system.
ANAC may apply penalties from €500 to €2,500, without prejudice to criminal or civil liability.
