EthicsPoint - Align Technology Inc.

Reporting Security & Confidentiality

About EthicsPoint

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential incident management and reporting tool from NAVEX, a company that is the worldwide leader in risk and compliance management software and services. Align has engaged NAVEX to provide our employees, partners, and others with access to EthicsPoint as a way to ask questions and report concerns about actual or potential violations of law, our Code, Align Policy or Align conduct expectations.

The tool enables Align management and employees to work together to address potential fraud, abuse, and other misconduct in the workplace and behavior that doesn’t follow laws, Align’s Code of Conduct, Align Policies and/or other Align conduct expectations.

Why do we need a system like EthicsPoint?

Our employees are one of our most important assets and we must maintain a positive work environment that supports Align’s purpose to transform smiles and change lives. By creating open channels of communication, we promote a positive, productive, and respectful work culture. An effective reporting system is one tool at Align that supports our efforts to foster a culture of integrity and ethical decision-making.

EthicsPoint is just one of the avenues to report a Speak Up; to see all options for Speaking Up at Align, please read our Speak Up Policy.

Reporting – General

May I report a concern or ask a question using either the Web or a phone call?

Yes. The EthicsPoint reporting tool enables you to file a confidential, anonymous report via a phone call or by submitting an online form on your computer or mobile device.

What types of situations should I report?

The EthicsPoint system allows employees to report any actual or potential violation law, our Align Global Code of Conduct (“Code”), Align policies or other Align conduct expectations. You can also review our Speak Up Policy for additional details on the type of concerns that should be reported and our other reporting avenues.

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

When you observe some behavior that you believe violates our Code, we expect you to report it via any avenue described in our Speak Up Policy, including your manager, legal, human resources or other member of our management team. We recognize, however, that there may be circumstances when you are not comfortable reporting the concern via one of those avenues and that is why we have made this EthicsPoint reporting tool from NAVEX available.

Why should I report what I know?

We strive to foster a positive environment at Align and we want to know if you know or suspect that someone is not following the law, our Code, Align Policy or other Align conduct expectation. By working together, we can maintain a healthy and productive environment.

Does management really want me to report?

Yes, management at Align does, and in fact, expect you to raise your concern or ask a question when you think there is an actual or potential violation of law, our Code, Align Policy or other Align conduct expectation. As an Align employee, partner or customer, you may have initial knowledge of an activity that may be cause for concern.

Also, we do not want you to investigate – we have a full, fair and compliant inquiry process to look into and resolve concerns and questions that are raised. Your reporting ensures that all employees and partners are held to the same standards and that creates a better working environment for everyone.

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPoint secure server. NAVEX then makes the reports available only to specific authorized Align people who are charged with the responsibility of evaluating the report, based on the type of violation and location of the incident. Each of these report recipients has experience with handling reports confidential to the extent allowed by law and Align policy.

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

No. EthicsPoint is a positive aspect of our overall philosophy that allows us to ensure a safe, secure, and ethical workplace. You are encouraged to report a concern, seek guidance on an ethical dilemma, or ask a question. Effective communication is critical in today’s workplace and this is a great tool to enhance communication.

We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment.

Reporting Security & Confidentiality

It is my understanding that any report I send from a company computer generates a server log that shows every web site that my computer connects with. Will 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 computer or device to EthicsPoint is available.

If you feel uncomfortable making a report on your work computer or device, you have the option of using a computer or device outside of work and connecting to the EthicsPoint secure website. In fact, many people choose this option - NAVEX’s data shows that fewer than 12% of reports are generated during business hours.

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

According to NAVEX, making a report from home, a neighbor’s computer, or any internet portal does remain secure and anonymous. Also, according to NAVEX, internet portals do not identify visitors by screen name and also the EthicsPoint system strips away internet addresses so that anonymity is 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 NAVEX EthicsPoint system is designed to protect your anonymity. However, if you wish to remain anonymous, you - as a reporter – should be careful to ensure that the body of the report does not reveal your identity. For example, “From my cube next to Jan Smith…” or “In my 33 years…”.

Is the phone toll-free helpline 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.

What if I want to be identified with my report?

There is a section in the report to identify yourself if you wish. We do encourage reporters to identify themselves as it can help us understand the concern better and work to resolve it. Also, Align prohibits retaliation against good faith reporters so you can feel comfortable that retaliation for good faith reporting is a separate violation of our Code that we take seriously.

Tips & Best Practices

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

Ethical behavior is a core element of Align’s Code of Conduct. All unethical conduct, at any level, ultimately hurts the company and distracts from our mission of transforming smiles and changing lives.

Consider what happened in recent corporate scandals you may have read in the news 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, please consider it your responsibility 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?

Speak Up. All reporting avenues are provided in our Speak Up Policy and you can use this NAVEX portal to report a concern or raise a question. It is better to report a situation that turns out to be harmless than to let possible unethical behavior go unchecked.

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, EthicsPoint mobile, 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 phone 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 in the time specified to answer company questions. You and the company now have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

Are these follow-ups on reports as secure as the first one?

All subsequent EthicsPoint correspondence is handled the same 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. You should 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 phone, computer or device that can access the internet. You can file from home and many public locations, including the public library, have computers with internet access. EthicsPoint web, mobile and phone are each available 24 hours a day, 365 days a year. Also, you may always report a concern or raise a question under any of the options set out in our Speak Up Policy.