Business Integrity
At MEDIUS d.o.o., we recognize the importance of ensuring business integrity and anti-corruption, which is why we have adopted a policy that encourages all stakeholders to report any observed events in the work environment that may constitute violations of applicable regulations in the Republic of Slovenia and internal company rules. This includes potential breaches of the company's internal acts, if they do not prescribe a different procedure or body for handling violations, as well as reports of illegal, unethical, or otherwise questionable behavior.
An effective internal system for reporting violations and protecting whistleblowers promotes the spread of a culture of lawful business conduct in the company and provides an opportunity to improve the business environment, both organizationally and ethically. This policy regulates the reporting system, ensuring that the identity of the reporter remains confidential (whether the report is anonymous or non-anonymous) and that the reporter is not exposed to potential punitive, unfair, or discriminatory actions.
The policy precisely describes:
various methods and communication channels available to the reporter,
the notification process activated upon the submission of a report,
different stages of the process,
roles and responsibilities of the individuals involved in the process.
Integrity, prevention of corruption, incorruptibility, and compliance with laws are crucial for our sustainable success and form the foundation of our corporate culture.
We respect applicable laws, regulations, this code of conduct, and company policies and guidelines. We are trustworthy and honest business partners to our colleagues, candidates, clients, suppliers, and all other stakeholders. We promote an inclusive work environment and treat each other with respect and dignity. We regularly educate ourselves on key mandatory topics such as integrity, compliance with laws, data protection, diversity and inclusion, IT security, and health and safety.
In case of issues, we turn to our immediate supervisors, the integrity officer, the employee representative, or the company's management.
Immediate supervisors play a crucial role in creating a culture of integrity and respect within their teams and are responsible for:
regularly discussing with their teams the importance of ethical and compliant work;
promoting and developing an environment of open communication and respectful and inclusive dialogue within their teams, including on ethical issues and concerns;
setting an example of expected behaviors and adherence to the values of MEDIUS d.o.o.
Laws
We do not tolerate violations of laws, regulations, this code of conduct, or our internal policies and guidelines. Violations may lead to disciplinary actions, including possible termination of employment, as well as legal consequences in accordance with the applicable legal framework.
Prevention of Bribery and Corruption
We believe that our success is due to the high quality of our services, and we strongly oppose bribery and corruption in all forms. We do not offer, give, or accept any benefits or gifts intended to unfairly influence individuals in government or business circles, with the aim of gaining an unfair commercial advantage or obstructing the fair functioning of justice. We strive to avoid even the appearance of improper influence, regardless of where we operate or the culture we represent. We comply with all applicable laws governing the prevention of bribery and corruption.
Hospitality and Gifts
For MEDIUS d.o.o., it is crucial to establish good working relationships with its business partners. It is understood that in the context of these relationships, small gifts and hospitality may be accepted that can help strengthen this relationship. However, it is essential that any offered, given, or received gift or hospitality meets certain guidelines:
Legality: All gifts and hospitality must comply with applicable law;
Proportionality: Gifts and hospitality must be reasonable and proportionate to the nature of the business relationship and should not exceed common business practices;
No expectation in return: Gifts or hospitality should not be associated with unfair expectations or demands for special favors or benefits in return.
Fair Competition
Our commitment to fair competition is a fundamental value that we respect, and we strive to maintain integrity and transparency in all our business relationships. We do not engage in any activities or agreements that could unfairly restrict competition or involve improper collusion or agreements with competitors. We do not make agreements with competitors about commercial terms affecting our clients or candidates, nor do we share competitively sensitive information about our market approach.
Confidential Information and Third-Party Intellectual Property
We are committed to respecting the intellectual property rights, trade secrets, and confidential information of others. Our priority is to protect all non-public information, whether generated internally or entrusted to us by third parties, including clients, suppliers, and individuals.
We commit to using or disclosing only those pieces of information that are reasonable and in line with local law and our contractual obligations. We do not seek to gain advantage by violating the intellectual property rights or confidential information of others. Respect for privacy and the protection of information are central values of our operations.
Third-Party Integrity
Our operations are based on honesty, and we expect our business partners to adhere to the same high ethical standards. In selecting business partners, we are diligent and require them to comply with high ethical, social, and environmental standards. We do this to protect our company's reputation and ensure that we do not engage in activities that do not meet our expectations of social and ethical conduct, regardless of where these activities take place. This emphasizes our commitment to sustainable and ethical business practices and strives to establish relationships with partners who share the same values and standards.
Forgery, Misappropriation, Deception, Collusion
We are committed to safeguarding property, both our own and that of our business partners. We do not tolerate any forms of unethical actions, including theft, fraud, embezzlement, deception, collusion, forgery, or illegal appropriation of MEDIUS d.o.o.'s or third parties' property. Respect for property is central to maintaining integrity and trust in our business relationships.
Data Protection
MEDIUS d.o.o. shows respect for the privacy rights of its partners, colleagues, candidates, and other stakeholders. We treat all personal data we receive with the utmost care and handle it in accordance with applicable data protection and privacy laws. The security and confidentiality of personal data are crucial to our operations, and we strive to ensure their proper protection and compliance with all applicable data protection regulations.
Communication and Reputation
Reputation and brand are of immense importance to our company. To effectively protect them, we follow the principles of open, accurate, timely, and legally compliant communication. We ensure that only authorized personnel can disseminate information, publicly speak, or post on social media on behalf of MEDIUS d.o.o. This approach allows us to maintain a high level of integrity and consistency in our communication while adhering to all legal requirements governing communication and advertising. This ensures that our reputation remains strong and our brand remains trustworthy.
Financial Integrity
Accurate financial records are crucial for business integrity. We ensure the creation of complete books and records that accurately reflect the nature of the transactions and activities they document. Where necessary, we report our financial transactions to government agencies in a timely and objective manner. We ensure that internal and external reports comply with applicable legal regulations and standards and our internal policies. This maintains a high level of transparency, legality, and accountability in our business operations, building stakeholder trust and ensuring timely and reliable information about our financial condition and business activities.
Reporting
We promote a culture that encourages questioning and seeking guidance, especially regarding the principles outlined in this Policy and our internal policies and guidelines. Expressing concerns about potential improper business conduct and reporting actual or suspected wrongdoing allows MEDIUS d.o.o. to conduct effective investigations, support fair and consistent rule enforcement in the workplace, and take action to prevent further inappropriate behavior. Reports can lead to improvements in internal controls, business processes, and practices, and help ensure that everyone within our business activities acts fairly and in compliance with regulations.
We encourage employees and external stakeholders to discuss any concerns directly with the appropriate contact point within the company:
to their superior or
to a member of the management team.
Protection Against Retaliation
MEDIUS d.o.o. prohibits any form of retaliatory actions, intimidation, or disciplinary measures against anyone who, in good faith, reports a violation or leads or participates in an investigation, even if it is eventually determined that no violation occurred. Colleagues and employees involved in retaliatory actions or intimidation are subject to disciplinary measures, up to and including termination of employment, and may face other consequences in accordance with the law. If a reporter is concerned about facing retaliation, they should immediately contact the authorized integrity officer at MEDIUS d.o.o.