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About the Cooper Standard IntegrityLine and NAVEX
What is the Cooper Standard IntegrityLine?
At Cooper Standard, integrity drives us to be honest, ethical and responsible. We expect our stakeholders to speak up to report concerns and ask questions when something doesn't seem right. We offer a variety of ethics reporting resources, including the Cooper Standard IntegrityLine, which is a comprehensive and confidential reporting tool to assist management and employees to work together to address fraud, abuse, and other misconduct in the workplace, all while cultivating a positive work environment. The Cooper Standard IntegrityLine is available to accept reports online or by telephone and is answered and administered by an external company, NAVEX.
What is NAVEX?
NAVEX is the third-party administrator of the Cooper Standard IntegrityLine.
Why do we need a system like the Cooper Standard IntegrityLine?
By creating open channels of communication, we can promote a positive work environment and maximize productivity. Publicly traded companies are required by law to have an anonymous reporting vehicle to address accounting and auditing fraud directly to the audit committee. An effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision-making.
REPORTING – GENERAL
May I report using either the Internet or the telephone?
Yes. With the Cooper Standard IntegrityLine, you have the ability to file a report via either the telephone or the internet.
What type of situations should I report?
The Cooper Standard IntegrityLine is designed for employees and third parties to report any violation of our stated Code of Conduct, or another concern you may have, and to ask questions or seek guidance related to our company's policies and procedures.
What if this is an emergency?
Please seek local authorities or emergency services.
If I see a violation, shouldn't I just report it to my manager, security, or human resources and let them deal with it?
When you observe behavior you believe violates our code of conduct, we expect you to report it. You should bring any concerns forward to your manager, your human resources representative or other member of our management team, including the ethics and compliance office, which can be reached email at ethicsandcompliance@cooperstandard.com. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances we have partnered with NAVEX to provide the Cooper Standard IntegrityLine. We would rather you report anonymously (where permitted by local laws) than keep the information to yourself.
Why should I report what I know? What's in it for me?
We all have the right to work in a positive environment. 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 and productive environment. Corporate misconduct can threaten the livelihood of an entire company.
Where do these reports go? Who can access them?
We certainly do. In fact, we need you to report. You know what is going on in our company - both good and bad. 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.
Isn't this system just an example of someone watching over me?
The Cooper Standard IntegrityLine is designed support our core values and 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.
How does Cooper Standard investigate and resolve concerns?
After a report is made, a small team comprised of Cooper Standard legal department members will review the information you provide and take appropriate action to investigate. You will not be provided with the details of resolution but the status of your report will show "closed" when all appropriate action and investigation are complete. You can log in with your report key and password to check the status of your report. Any allegations of improper conduct received through EthicsPoint are investigated in accordance with local law, and applicable Company policies and procedures, including, but not limited to, the Code of Conduct and the Ethics Reporting Response Policy.
REPORTING SECURITY & CONFIDENTIALITY
It is my understanding that any report I send from a company computer generates a server log that shows every website my computer connects with; won't this log identify me as a report originator?
NAVEX, the administrator of the Cooper Standard IntegrityLine, does not generate or maintain any internal connection logs with IP addresses; no information linking your computer to the NAVEX system is available. In fact, NAVEX is contractually committed not to pursue a reporter's identity.
If you feel uncomfortable making a report on your work computer, you have the option of using a computer outside our work environment (such as one located at an Internet café, the library, at a friend's house, etc.) through the NAVEX secure website. Many people choose this option, as NAVEX's data shows that fewer than 12% of reports 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, where permitted by local laws. An Internet portal never identifies a visitor by screen name and the NAVEX system strips away identifying information, such as an IP address, so that anonymity is maintained. Plus, NAVEX is contractually committed not to pursue a reporter's identity.
I am concerned the information I provide NAVEX through the Cooper Standard IntegrityLine will ultimately reveal my identity. How can you assure me that will not happen?
The NAVEX system is designed to protect your identity. In fact, NAVEX is contractually committed not to pursue a reporter's identity. To further ensure your anonymity, you - as a reporting party - need to be careful not reveal any identifying details as part of your report. For example, "from my cube next to Jan Smith … " or "in my 33 years … "
Is the telephone toll-free hotline confidential and anonymous too?
Yes – so long as anonymous reporting is permitted by local laws. You will be asked to provide the same information you would provide in an Internet-based report; the interviewer will type your responses directly into NAVEX's secure environment. Phone-line-based reports have the same security and confidentiality measures applied to them during delivery as Internet-based reports.
What if I want to be identified with my report?
There is a section in the report where you may identify yourself, if you wish.
What if I face retaliation?
Cooper Standard has a strict non-retaliation policy. We will not tolerate retaliation against anyone who in good faith raises a concern, reports misconduct or participates in an investigation. We prohibit taking negative action against any colleague or associate for reporting a possible deviation from this policy or for cooperating in an investigation. Any individual or employee who retaliates against another individual or employee for reporting a possible deviation from our non-retaliation policy or for cooperating in an investigation will be subject to disciplinary action, up to and including termination.
TIPS & BEST PRACTICES
I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?
At Cooper Standard, integrity drives us. We choose to promote ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. One only has to consider what happened in recent corporate scandals to see the disastrous effects a seemingly harmless lapse in ethics can have on an otherwise healthy company. If you know of any incidents of misconduct or ethical violations, consider it 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. When you call the Cooper Standard IntegrityLine, the NAVEX operator can help you prepare and file your report so it can be properly understood. The online report template will also help you present the information required to support a review of your concerns. We would rather you report a situation that turns out to be harmless than let possibly unethical behavior go unchecked because you were unsure.
What if my boss or other managers are involved in a violation? Won't they get the report and start a cover-up?
The Cooper Standard IntegrityLine system and report distribution protocols are designed by NAVEX so that implicated parties are not notified about 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?
When you file a report, either using the Internet or through NAVEX's Contact Center, you receive a unique report key and are asked to select a password. With the report key and your password, you can return to the Cooper Standard IntegrityLIne system again, either by Internet or telephone, and access the original report. At that point, you can add more details.
What if you have questions for me concerning my report?
The Cooper Standard IntegrityLine provides functionality that enables company representatives to post questions for you, even if you report anonymously. When you receive your report key, you will be provided with the amount of time we expect for the report to be processed. When that time has passed, we strongly suggest you check to see if any questions have been posted. Providing the opportunity for such dialogue means situations may not only be identified but can also be resolved, no matter how complex.
Are these follow-ups on reports as secure as the first one?
All correspondence through the Cooper Standard IntegrityLine are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity, if you so choose (and where permitted by local laws).
Can I still file a report if I don't have access to the Internet?
You can file a report from any computer that can access the Internet. You can file from home. Many public locations, including most public libraries, have Internet computers. If you don't have access or are uncomfortable using a computer, you can call the Cooper Standard IntegrityLine toll-free number which is available 24 hours a day, 365 days a year. Dialing instructions vary by country; verify the proper dialing instructions with a local team member.
What should I do if the telephone number is not working?
If the telephone number listed on this site or the posters in your facility is not functioning, please make your report online through this web site. Please indicate in the report that the telephone number did not work.
What should I do if the country I am in is not listed above?
If there is no telephone number provided for your location, please make your report online through this web site. Please indicate in the report that dialing instructions for the country you are located in were not available.