Reporting – General
Reporting Security & Confidentiality
Tips & Best Practices
About EthicsPoint
What is EthicsPoint?
EthicsPoint is a confidential reporting tool created by NAVEX.
It’s responsible for the following:
- Receiving confidential web-based reporting of concerns about any potential violation of laws, regulations, principles contained in Menarini Global Code of Conduct and/or internal policies and/or procedures.
- Protecting the identity of reporters who wish to remain anonymous, where permitted under local laws and;
- Transmitting information to Menarini for investigation.
Why do we need a system like EthicsPoint?
We believe that our employees are the most powerful element when considering the development of our Company.
By creating open channels of communication, we can promote a positive work environment.
An effective reporting system augments our other efforts to foster a culture of integrity and ethical decision-making.
Reporting – General
How do I use the Ethicspoint to report my concerns?
With the Ethicspoint, you may complete a report on the website.
You have the ability to report anonymously, if permitted under local law.
What types of situations should I report?
The EthicsPoint system allows to report any violation, even potential, of laws, regulations, principles contained in Menarini Global Code of Conduct and/or internal policies. Do not hesitate to report any concerns you have as Menarini group is eager to consider all situations that prevent our employees to work efficiently in line with ethical standards.
If I see a violation, shouldn't I just report it to my manager, compliance functions. or human resources?
As with matters of sensitive nature, your first option is to always raise concerns with y your line manager, the Compliance functions and/or the HR department. If you are uncomfortable with the direct approach of discussing your concern in the manner described above, or if you feel that your concern has not been resolved, or if you prefer anonymity ( Where permitted under local laws), you should use the EthicsPoint
Why should I report what I know? What’s in it for me?
We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy environment. And, corporate misconduct can lead to consequences for an entire company as well as individual employees.
Does management really want me to report?
We certainly do. In fact, we need you to report. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the company and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.
Where do these reports go? Who can access them?
Reports are entered directly on the EthicsPoint secure server. NAVEX makes these reports available only to specific individuals within the company who are in charge of evaluating the report, based on the type of violation. Each recipient has had training and obligation to keep these reports in the utmost confidence.
Isn’t this system just an example of someone watching over me?
No. EthicsPoint is a positive aspect of our overall philosophy that allows us to ensure a safe, secure and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern. Effective communication is critical in today’s workplace and this is a great tool to enhance that communication.
We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment.
Reporting Security & Confidentiality
Can I report my concern anonymously?
We understand that in some situations, you may want to file a report anonymously. If you want to do so, and local law permits, the Ethics Point is designed to protect your anonymity. No attempt will be made to determine your identity through electronic or other means.
At the end of the web-based report, you will receive a report key and be asked to create a record ID.
Please retain your report key and record ID to monitor the progress on your concern or provide additional information, if necessary. This process also allows investigators to ask follow-up questions to anonymous reporters.
What if I want to be identified with my report?
There is a section in the report to identify yourself, if you wish.
Disclosing your identity and/or providing contact information can help to expedite an investigation. If you disclose your identity, Menarini will strive to protect the confidentiality of your identity to the extent possible, pursuant to any requirements provided for by the law.
What If I face retaliation?
Threats or acts of retaliation against individuals who make a good faith report will not be tolerated.
Anyone who retaliates or attempts to retaliate will be sanctioned.
Tips & Best Practices
I am aware of some individuals acting unethically, but it doesn't affect me. Why should I bother reporting it?
Our company promotes ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. You only have to consider what happened in recent corporate scandals worldwide to see the disastrous effects that a lapse in ethics can have on an otherwise healthy company. If you know of any incidents of misconduct or ethical violations, consider it is your duty to report it.
I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?
File a report. NAVEX can help you prepare and file your report so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked.
What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?
The EthicsPoint system and report distribution ensure that implicated parties are not notified or granted access to reports in which they have been named.
What if I remember something important about the incident after I file the report? Or what if the company has further questions for me concerning my report?
When you file a report at the EthicsPoint Web site, you receive a unique, randomized number called a “Report Key” and are asked to choose a password. You can return to the EthicsPoint system again either by Internet and access the original report to add more details or answer questions posed by a company representative. We strongly suggest that you return to the site in the time specified to answer company questions. You and the company now have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex they are.
Are these follow-ups on reports as secure as the first one?
All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.
What if I lose my Report Key or forget the Password I created?
To ensure that security and confidentiality is maintained, if you lose your report key or password, you will need to file a new report. Mention in the new report that it is related to a report or question you previously submitted.
Can I still file a report if I don’t have access to the Internet?
You can file an EthicsPoint report only from any computer that can access the Internet. Many public locations, including the public library, have Internet computers. If you are not comfortable with on-line reporting tools, use any convenient means you prefer, regular post mail, call etc. You may find contact details for all Menarini companies in all countries we operate on Menarini web site.