EthicsPoint - QVC, Inc.

Reporting Security & Confidentiality

About EthicsPoint

What is EthicsPoint?

EthicsPoint is a reporting tool created by NAVEX that gives team members an opportunity to report concerns regarding misconduct and violations of policies, standards, or the law. EthicsPoint also offers the option for team members to do so in a confidential and anonymous manner. Team members may also utilize EthicsPoint to ask questions or seek guidance regarding Company policies.

Why do we need a system like EthicsPoint?

Our team members are our most important asset. By creating open channels of communication and various options for raising concerns, we promote a positive work environment and maximize productivity.
An effective reporting system supports our other efforts to foster a culture of integrity and ethical decision-making.
EthicsPoint provides team members an avenue to report concerns or ask questions anonymously if they are uncomfortable being identified.

Reporting – General

May I report using either the Internet or the telephone?

Yes. EthicsPoint enables you to file a report via either the telephone or the Internet. You can do so on a confidential and anonymous basis if you choose.

What types of situations should I report?

The EthicsPoint system allows team members to report any violation or suspected violation of Company policies, standards, or the law, or to raise any other types of concerns. EthicsPoint can also be used to ask questions or seek guidance regarding Company policies.

If I see a violation, shouldn't I just report it to my manager and let them deal with it?

When you have a concern about a violation, we expect you to report it. Ideally, you will feel comfortable raising concerns to your direct manager or other member of our management team. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. EthicsPoint is an option you can use if you are uncomfortable reporting through your manager or other available reporting channels , or when you prefer to report anonymously.

Why should I report what I know? What’s in it for me?

We strive to create a positive work environment for all team members. Creating such an environment requires team members to act in an ethical manner and inform the appropriate people of concerns. By working together, we can maintain a healthy and productive environment. Furthermore, some forms of corporate misconduct can put the Company at significant legal or reputational risk, making reporting of concerns a key to the Company’s health and success.

Does management really want me to report?

We certainly do. In fact, we need you to report. You may have insight that others do not have. Your reporting can minimize the potential negative impact on the Company and team members.

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 charged with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients understands the importance of keeping the reports as confidential as possible.

Isn’t this system just an example of someone watching over me?

No. EthicsPoint reflects our priority of ensuring a safe, secure, and ethical workplace. You are encouraged to seek guidance on ethical dilemmas or communicate a concern. Effective communication is critical in today’s workplace and this is a great tool to enhance that communication.

Reporting Security & Confidentiality

It is my understanding that any report I send from a Company computer generates a server log that shows every website that my PC connects with. Won’t this log identify me as the report originator?

NAVEX does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available.

If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside our work environment (such as one located at an Internet café or at a friend’s house) through the EthicsPoint secure website. Many people choose this option, as NAVEX data shows that fewer than 12% of reports are generated during business hours.

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is totally maintained.

I am concerned that the information I provide EthicsPoint will ultimately reveal my identity. How can you assure me that will not happen?

The EthicsPoint system protects your anonymity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that what you say in your report does not reveal your identity by accident. For example, you should avoid sharing certain details that could inadvertently reveal your identity such as stating, “From my cube next to Jan Smith…” or “In my 33 years with the Company…”.

Is the telephone toll-free hot line confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the EthicsPoint Web site. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the report to identify yourself, if you wish. It is entirely your choice whether your EthicsPoint report is anonymous or not.

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 team members, including you. You only have to consider what happened in past corporate scandals 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, it is your duty to yourself and your coworkers 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 even if you are unsure. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked. EthicsPoint can also be used to ask questions about policies or otherwise seek guidance.

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 or through the EthicsPoint Call Center, 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 or telephone and access the original report to add more detail or answer questions posed by a Company representative. We strongly suggest that you return to the site periodically because the Company will often add questions for you to assist them with their review or investigation.

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.

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 from any computer that can access the Internet. You can file from home. Many public locations, including the public library, have Internet computers. If you don’t have access to or are uncomfortable using a computer, you can call the EthicsPoint toll-free hotline, which is available 24 hours a day, 365 days a year.