Welcome to IMC Corporate Misconduct Hotline
IMC Company (hereinafter - Company) adheres 10 rules of IMC. According to which the IMC prohibits:
- discrimination of employees in any form;
- lies and dishonesty in the relations between colleagues;
- dishonesty, indifference, negligence and irresponsibility;
- harassment and other behavior that can offend or suppress another;
- theft, excessive usage and waste of the Company resources and working time;
- any types of corruption.
What is IMC Corporate Misconduct Hotline?
IMC Corporate Misconduct Hotline is:
- a system for collecting and processing whistleblowing reports uncovering violations of company policies and corruption offenses;
- modern intake and feedback channels for anonymous misconduct reporting;
- incident management software for instant risk/priority triage and reaction as well as the robust case management system.
The service is organized for the purpose of obtaining information about fraudulent, corrupt and other misconduct that harm the interests of the Company, its current or potential partners.
Who can report?
Any individual or representative of a legal entity may report violations in the IMC, related legal entities, as well as in its subsidiaries.
What can you report?
In addition to the violations mentioned above, you can also report:
- unfair competition in tenders;
- misappropriation or misuse of Company's assets;
- disclosure of confidential information or insider dealings;
- violation the Company's policies and / or applicable laws of Ukraine;
- industrial or environmental health and safety issues;
- rights abuse by management, abuse of authority, violations of employees' human rights.
How to report?
You can report using following ways:
- Visit the secure portal by following the link imc.ethicontrol.com or imc.e.co.ua.
- Call 0 800 211 524. Toll free calls from numbers of all operators are accepted on weekdays from 09:00 to 18:00 (leave a message on the answering machine during non-working hours).
- Send an email to email@example.com.
The Service does not register:
- claims and complaints of consumers and customers for the Company's products or services, as well as other claims within the Law of Ukraine "On Protection of Consumers' Rights";
- complaints at third parties that are not the Company's business partners;
- complaints of home life issues or other problems that are outside the Company's responsibility and competence or its employees;
- threats to other persons;
- messages and requests in accordance with the Law of Ukraine "On requests of citizens."
You can report anonymously!
To ensure you full anonymity and the impartiality of message registration, the Company hired an external independent service provider LLC Ethicontrol. The independent provider is responsible for managing calls and web-portal messages intake, as well as protection of your anonymity. If you do not want to reveal yourself, nobody will do it without your consent. The information you provide is confidential to the extent permitted by applicable laws.
What happens after report submission?
- The external contractor records your report and transfers it immediately to the Company's Head Office for initial review.
- The initial review is an assessment of the adequacy and completeness of the report. The issue is being triaged and passed to responsible employees for solving it.
- At the review stage, in the information insufficiency, further processing of your concern may be suspended until you answer additional questions via the Service's Web Feedback Room. Responsible team lead and a case team are assigned to each report. They are up to investigate the incident and solve your issue.
- You will be contacted by the case team within 30 days from the date of report origination. You will be notified on case status changes, asked additional information or informed about the investigation and response activities.
- You can anonymously communicate with the case team anytime sharing additional files or giving feedback via the Web Feedback Room. You may also change your access credentials, add or change contact information. Optionally, you can leave your email address to receive automatic notification about status changes or receipt of comments from the Company.
- After the case resolution, you will be able to assess and provide feedback comments regarding the response team and the adequacy of actions taken.
- The Company guarantees the confidentiality of individuals who report fraud and corruption.
- The report intake is carried by an independent third party.
- All of the incoming reports (100%) must be registered, provided that they contain the minimum information necessary for the next steps.
- Each report is being reviewed carefully.
- The information is reviewed only by persons who are not biased and involved in the relevant process, allowing them to objectively and independently define facts and draw conclusions.
- In case the reported information is confirmed the case will be submitted to the top management of the Company to take urgent remediation actions.
- Specific remediation actions always depend on the nature and severity of the violation.
- In order to keep the privacy and anonymity of all the stakeholders, the reporter may not know immediately about the existence of the investigation or its results.
- Any terminology used above should be interpreted in accordance with the legislation of Ukraine.