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SiriusPoint Ltd
Abuse of or Fraud with Company Benefits Improper, misleading or deceptive actions taken, falsification of records, or misrepresentation of physical conditions related to benefits plans including health and supplemental income plans, tuition reimbursement and sick or other paid time off programs.
Accounting, Auditing and Internal Financial Controls Concerns regarding questionable practices relating to accounting, auditing or internal financial controls. (Examples include, but are not limited to: misstatement of revenues or documents relating to revenue, misstatement of expenses, misstatement of assets, or misapplication of GAAP principles)
Antitrust and Price Fixing Potential or actual existence of oral or written agreements, arrangements or understandings with third parties to fix prices; boycott specific suppliers or customers; allocate products, territories or markets; or exchange competitively sensitive information; as well as discussions regarding price, trade allowances or rebates, costs, competition, marketing plans or studies, production plans and capabilities or any other confidential information.
Code of Ethics / Access Person Inquiries Potential or actual matters related to the Company’s Code of Ethics and Access Person responsibilities.
Conflict of Interest A conflict of interest is defined as a situation in which a person, such as a public official, an employee, or a professional, has a private or personal interest sufficient to appear to influence the objective exercise of his or her official duties. (Examples include: inappropriate vendor relations, bribery, misuse of confidential information, inappropriate customer relations)
Disclosure or Misuses of Confidential Employee/Customer Information and Data Potential or actual disclosure, use, or misappropriation of customer and/or employee non-public information held by the Company. This includes, but is not limited to, improper disclosure, use or misappropriation of Protected Health Information (potential violation of the Health Insurance Portability and Accountability Act). Also refers to the technical, contractual, administrative and physical steps taken by the Company to protect against unauthorized access to and disclosure of personally identifiable data of employees, customers and other third parties that the Company possesses.
Discrimination or Harassment Uninvited and unwelcome verbal or physical conduct directed at an employee because of his or her sex, religion, ethnicity, or beliefs. (Examples include: bias in hiring, bias in assignments, wrongful termination, bias in promotions, bias in educational decisions, unfair compensation, inappropriate language).
Embezzlement To appropriate (as property entrusted to one's care) fraudulently to one's own use. (Examples include: bookkeeping errors, misapplication of funds, and mishandling of cash)
Falsification of Work-related Books and Records, and Time Abuse Potential or actual falsification of books and records relating to an employee’s work hours, vacation time, work reports, and other records. This includes, but is not limited to, monthly reports and time sheets.
Fraud Fraud can be defined as the intentional misrepresentation or concealment of information in order to deceive, mislead, or acquire something of value. A fraud is an intentional deception perpetrated to secure an unfair gain. (Examples include: Embezzlement, Violation of Policy, Theft, Sabotage)
Gifts and Entertainment Refers to the inappropriate offering, solicitation or accepting of items of more than nominal value from vendors, customers or other third parties in a capacity as an employee of the Company.
Improper Lobbying, Political Contribution, or Payments to Labor Unions Inappropriate activities that are potential or actual violations of federal, state, and foreign lobbying, political action, and labor union laws, including the improper contribution or acceptance of funds.
Improper Records Creation, Retention or Destruction Matters related to Company policy or directives surrounding records creation, retention and destruction.
Improper Use or Disclosure of Company or Third-Party Confidential Information, Intellectual Property or Trade Secrets Potential or actual unauthorized use or disclosure by an employee of the Company’s or a third party’s confidential information, intellectual property or trade secrets. This includes, but is not limited to, confidential transactions (sales, mergers or acquisitions), confidential documents, intellectual property (trademarks, copyrights, patents), trade secrets, marketing and other corporate data bases, marketing plans, business proposals and strategies, and non-public financial or pricing information.
Misconduct, Inappropriate and/or Offensive Behavior Potential or intentional wrong doing, such as deliberate violation of a law or standard. Also refers to the potential use of inflammatory, derogatory, unduly critical or insulting communications to an employee, customer, or other individual with a business relationship with the Company.
Misuse of Company Assets, Facilities, and/or Services Potential or actual misuse of Company assets, facilities, equipment, services or other resources by an employee for personal, non-business reasons. This includes, but is not limited to, personal use of Company e-mail, software and internet access; and the use of unauthorized software on Company-owned systems.
Physical Theft, Sabotage, and Vandalism Potential or actual unauthorized and/or unlawful physical taking or destruction of Company property.
Retaliation for Reporting Compliance Issues Potential or actual verbal, physical, written, or financial discriminatory or harassing behavior toward an individual who has made a good faith report regarding a compliance issue.
Substance Abuse Potential or actual matters related to the misuse of both legal and illegal drugs including alcohol. This includes, but is not limited to, the use/misuse of cocaine, narcotics, marijuana and stimulants.
Suspected Money Laundering and/or Fraud Schemes Potential or actual activities related to concealing the source of money obtained from serious crimes, such as drug trafficking or terrorist activity.
Suspected Non-Compliance with Company Policy and Procedures / Legal Requirements Actions or activities that are potentially in violation of the Company’s policies, procedures, code of conduct, and/or legal requirements. This includes, but is not limited to, CHR policies and procedures.
Unfair Trade Practices, Deception, and Fraud Potential or actual matters related to unfair trade practices, and misleading sales, marketing, and advertisements. This includes, but is not limited to, misrepresenting, creating misleading impressions, omitting important facts or making false claims about the Company's or its competitors' products or services.
Violations of Environmental Protection, Health or Safety Law Potential or actual violations of any environmental, health or safety law, regulation, corporate policy or procedure that the Company is required to abide by (e.g., OSHA, EPA, ADA, FMLA). This includes, but is not limited to, risks to the health and safety of employees or third parties, environmental damage, and poor housekeeping.
Violence or Threats directed at an Employee Potential verbal or physical threat of harm, evil, injury, or damage to the person or property of an employee by the Company or another employee of the Company. This includes, but is not limited to, direct, veiled, conditional and violent threats.
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