Customer Reports in EthicsPoint

About EthicsPoint

How and What to Report

Reporting Security & Confidentiality

Tips & Best Practices

Customer Reports in EthicsPoint

For issues/questions regarding your accounts or other banking products and services, is the EthicsPoint hotline the right resource for me?

No. To quickly receive the help you need, please call one of the customer service numbers listed below or visit the First Citizens Customer Service site for additional resources to meet your specific needs:

As a customer, when should I use the EthicsPoint hotline?

When you want to report something you’ve seen or experienced that you feel could be a violation of law (e.g., unfair treatment, bullying, harassment, discrimination, etc.), regulations, our Code of Ethics, or other ethical issues. You can report anonymously if desired.

About EthicsPoint

What is EthicsPoint?

EthicsPoint is the confidential EthicsPoint hotline that provides a way to report violations or potential violations of our Code of Ethics, any stated company policy, or any law, rule or regulation. While this secure online website is managed by NAVEX, a third-party service provider, First Citizens will address your report with respect and confidentiality throughout the process. You may choose to include your name and contact information or, where permitted by local law, remain anonymous. You have the option to file your report by phone or use the secure online form found on this website.

Why do we have a confidential reporting hotline like EthicsPoint?

Please Note: The EthicsPoint hotline is not an Emergency Service. Please do not use the hotline to report events that present an immediate threat to life or property. Reports submitted through this service may not receive an immediate response. If you require emergency assistance, please contact local authorities.

How and What to Report

May I report using either the Internet or phone?

Yes, you may file a confidential, anonymous report by phone or online, 24 hours a day, seven days a week, any day of the year. Access the online version here: EthicsPoint - First Citizens Bank

Our EthicsPoint hotline numbers are as follows with greetings in English (additional languages available as listed):

What types of situations should I report?

First Citizens encourages you to raise any ethical issue that does not feel right to you. Any First Citizens’ associate, customer, or vendor, or anyone doing business with us, may contact our EthicsPoint hotline to report an ethical concern, including if you suspect or become aware that any associate, or someone working on First Citizen’s behalf, may have engaged in misconduct.

Doing the right thing includes speaking up when we believe someone has engaged in conduct that raises ethical concerns. All First Citizens Bank associates have a duty to immediately report any suspected or potential violations of law, our Code of Ethics, our governance documents (e.g., policies, standards, etc.) or other conduct that conflicts with our values, including, but not limited to the following:

While we encourage you to first provide First Citizens with the opportunity to address an issue, we appreciate that this is not always possible. Nothing in the Code of Ethics prohibits associates from communicating with government, regulatory agencies about possible concerns, or otherwise providing information to, filing a complaint with, or participating in investigations or proceedings with those agencies. There is also no requirement in the Code of Ethics that requires associates to notify First Citizens of any such communications.

Is there a better way to report HR issues?

If you feel you must remain anonymous, please report via the EthicsPoint hotline. Those reports to the EthicsPoint hotline about Human Resources (HR) related matters are forwarded to the HR Advisory team for review and follow-up. Following are other available options for reporting these types of issues:

What should I do if I believe I am the subject of retaliation for having raised a concern?

First Citizens wants all associates to feel comfortable and confident in raising questions and concerns. When concerns are raised in good faith, we do not tolerate retaliation of any kind, which includes discrimination, harassment, or other negative action taken against an associate for making a report. If you believe that you or someone else has been subjected to retaliation, please immediately report it to management, HR, or the EthicsPoint hotline.

What information should I provide in my concern?

Please help us to address your concern by providing all relevant information that you have available or indicating how additional information may be obtained. Please refrain, where possible, from using only first names, general locations, acronyms or other commonly used business terms that may make it difficult to review the concern. This is particularly important if you choose to report your concern anonymously.

Do I need some type of evidence or proof of an incident to report it?

No, providing evidence or proof of the incident is not required. A reasonable suspicion reported in good faith is enough. Of course, any details or evidence of a specific situation that you can provide are very helpful during the investigation.

If I see a violation, shouldn't I just report it to my manager, Security, or Human Resources?

When you observe some behavior that you believe violates our Code of Ethics, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager or other management team members. We recognize, however, that there may be circumstances when you are not comfortable reporting the concern in this manner. The EthicsPoint hotline is in place for these situations. We prefer you to report anonymously, instead of keeping the concern to yourself.

Why should I report what I know? How does reporting benefit me?

We all have the right to work in a positive environment and 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, associates can contribute to maintaining a healthy and productive environment at First Citizens.

Does management really want me to report?

Yes, we do. In fact, we need associates to report. You know what is going on - both good and bad. You may have initial knowledge of an activity or incident that may be cause for concern. Your reporting can minimize the potential negative impact to First Citizens, other associates, and our customers. Also, entering a concern may help identify issues that, when addressed, can improve First Citizens’ culture and performance.

Where do these reports go? Who can access them?

Reports are entered directly into the EthicsPoint third-party secure system. The report is then assigned by an Ethics and Privacy Compliance associate to one of our investigation partners based on the type of violation and location of the incident. Our investigation partners have had training in keeping these reports in the utmost confidence, only discreetly involving those parties necessary to bring it to resolution.

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

Absolutely not! Our EthicsPoint hotline is a positive aspect of our overall philosophy that 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 for our associates and customers alike.

If I’m contacted about a conduct concern, do I have to answer questions and/or provide information, if I’m asked to do so?

As is the case with any internal investigation, regardless of the initial source, you are required to participate as necessary as we thoroughly research the concern.

Reporting Security & Confidentiality

It is my understanding that First Citizens monitors all activity on company computers. If I send my report from a First Citizens’ computer or while logged into our network, will my IP address identify me as the person submitting the report?

No. All EthicsPoint hotline reports go through a third-party service provider that does not generate or maintain internal records with the source of the referral, including IP addresses and phone numbers, so no information linking your work computer to a report is available.

If you feel uncomfortable making a report on your work computer, you also have the option of using a computer outside our work environment (such as your personal computer or one located at a friend’s house, etc.) or through a mobile connection.

You also have the option to call into the hotline and the EthicsLine representative will document the information you provide.

Can I file a report from home and remain anonymous?

Regardless of the method, source, or location of your submission – whether you file online using a laptop, someone else’s computer, a public computer or you call from a mobile phone, a landline, etc. – all reports remain secure and anonymous. The EthicsPoint hotline strips away Internet addresses and phone numbers so that anonymity is totally maintained.

Can you assure me that the information I provide EthicsPoint will remain anonymous?

The EthicsPoint hotline and investigation process protects your anonymity whether you report via phone or online. However, please remember to provide sufficient details so an investigation can be conducted. If those details are lacking, the assigned investigation partner may request additional information from the anonymous reporter. If it is not provided, the investigation partner may need to close the investigation due to insufficient information.

If at any time during the investigation your identity is discovered, be assured your identity will be kept as confidential as possible and anyone that reports or provides information during an investigation in good faith is protected from retaliation. Any reprisal or retaliation against an associate for reporting in good faith is subject to Disciplinary Action. Please immediately report any retaliation you experience or see to your manager, HR, or use the EthicsPoint hotline.

What if my boss or other managers are involved in a violation? Will they see the report?

The EthicsPoint hotline and the confidential handling of the investigation ensures that anyone named in the report is not notified or given access to reports in which they have been named.

Are any follow-ups on the initial report as secure as the first one?

Absolutely, all EthicsPoint hotline correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity if you choose to remain anonymous.

What if I want to provide my name and contact information?

If you wish to identify yourself, there is a section in the report to do so. Whether you identify yourself or not, the investigation will still be handled confidentially and discreetly involving only those parties necessary to bring it to resolution.

Tips & Best Practices

I am aware of some individuals acting unethically, but it doesn't affect me. Why should I report it?

First Citizens promotes ethical behavior. All unethical conduct, at any level, ultimately hurts First Citizens and all associates, including you. Considering what has happened in recent corporate scandals, it is easy to see the disastrous effect that a 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 other associates 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 or feel right to me. What should I do?

Please file a report. If you call the EthicsPoint hotline, the representative can help you prepare and file your report so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked.

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 an EthicsPoint hotline report, you receive a unique, randomized number called a Report Key and are asked to choose a password. You can return to EthicsPoint again either by Internet or telephone and access the original report to add more detail or answer questions posed by an assigned researcher.

We strongly suggest that you return to the site within a few days of filing your report. You will need to use your Report Key and Password to access your report, and you will have the opportunity to answer any additional questions or provide more details. Please continue to follow up until the report is closed.

If you have raised your concern anonymously, it is important that you check back periodically to see if the investigator has any questions for you. Please note that if you choose to remain anonymous and do not follow up on your concern, the assigned researcher may be unable to obtain the additional information needed to investigate or address your concern and First Citizens will not be able to contact you about your concern.

If you do check back and there is no information for you, please be assured it does not mean that your concern is not being investigated.

What if I lose my Report Key or forget the Password?

To ensure that security and confidentiality is maintained, if you lose your Report Key or Password, you will need to file a new report. Please 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?

Absolutely, you can call our toll-free EthicsPoint hotline, which is available 24 hours a day, 365 days a year. Our EthicsPoint hotline numbers are as follows:

Will I learn the outcome when the investigation is complete?

Due to the sensitive nature of the resolution process and preserving the confidentiality of everyone involved, you may not be provided specific details regarding the outcome of your concern. However, please know that you will be informed when your report is closed and it will have been addressed in accordance with First Citizens’ policy.