A: NAVEX is a comprehensive and confidential reporting tool to assist management, employees, or external stakeholders to report suspected illegal or unethical conduct at TechnipFMC.

A: We want to create open channels of communication and promote a positive work environment. Allowing our employees to report concerns or simply ask questions to Compliance provides employees an avenue to discuss concerns in a manner that is most comfortable and convenient for them. An effective reporting system will enhance our other efforts to foster a culture of integrity and ethical-decision-making.

A: There are several avenues for employees to report concerns – you can reach out to your manager or someone else in management, People & Culture, your Region Compliance Counsel, other members of the Legal and Compliance team or the company’s Integrity Helpline.

A: Yes, you can report through the internet at Integrity Helpline or by telephone (numbers listed on the website)

A: Our Code of Business Conduct says that we, as TechnipFMC employees, are expected to report behaviors that may violate the guidelines set out in our Code and our policies. More importantly, we want to create a culture of integrity. We all have a right to work in a positive environment and need to let people know if someone is not acting appropriately. By working together, we can create and maintain a culture of integrity.

A: NAVEX is a communication tool providing an avenue for sharing information of any kind. You can ask questions through the system or report a work-related concern. A work-related concern is any suspected illegal or integrity wrongdoing, including but not limited to management issues, interpersonal relationships, favoritism, bullying, discrimination, harassment, retaliation, wrongful termination, health and safety issues, conflicts of interest, bribes, theft or fraud, misuse of information or government or law enforcement-initiated matters.

A: 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 taking the necessary actions to bring forward a concern if someone is not behaving appropriately. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the livelihood of an entire company.

A: You can use whatever avenue you feel most comfortable in reporting your concern. There are a few good reasons on why you should use NAVEX as well as reporting your concerns to management or People & Culture. First, NAVEX ensures that your report gets to the Compliance department for review. Second, by using NAVEX, you can remain anonymous and all report information is secure and held in strict confidence. You can also communicate directly with the investigation team through the portal with questions, responses and follow up details while remaining anonymous, should you prefer it.

A: Yes, you can select to report a concern or ask a question anonymously.

A: Yes! We certainly do. In fact we need you to report – if there is a problem we want to fix it. You understand what is going on in the company – the good and the bad. You have the knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the company and its people. If you do not speak up, then we might not know that there is an issue occurring.

A: Yes. NAVEX is an external site and does not generate or maintain any internal connection logs with IP addresses, so no information linking your computer to NAVEX is available. A report from home, a café or any internet portal will remain secure and anonymous.

No. If you do decide to provide your information, please know that we only share information with those who “need to know” to investigate and properly resolve the issue. Those are often limited to the Chief Compliance Officer and relevant members of the team. Management does not need to know where information came from, who reported the concern or participated in interviews.

A: 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 NAVEX website. These reports have the same security and confidentiality measures applied to them during delivery.

A: TechnipFMC has zero-tolerance on retaliation against employees for reporting suspected violations of our policies or Code of Business Conduct. We encourage employees and others to raise questions and concern to ensure that we are leading by example. Retaliation against anyone who makes a good faith report of possible violations of our Code or policies, or cooperates with an investigation, is strictly prohibited. When we say good faith, we mean that you have a reasonable belief that the information you are providing is truthful and you are not providing false information with malicious intent. Disciplinary action, including termination, could be a consequence for reporting in bad faith.

A: There is a section in the report where you may identify yourself, if you wish. We encourage reporters to identify themselves where they feel comfortable as a more open dialogue assists the Company in being able to investigate your concerns. The confidentiality safeguards applicable to anonymously reported cases also apply if you report a case and identify yourself.

A: Reports are entered directly on the NAVEX secure server to prevent any possible breech in security. NAVEX makes these reports available only to specific individuals within the company who are responsible for evaluating the type of violation and location of the incident. Each of these report recipients have received training in keeping these reports in the utmost confidence.

A: Yes, we have a Severity and Notification matrix that helps us determine the case severity level, appropriate management to be notified when allegations are received and key performance indicators (KPI’s) for case closure expectations. We use a 1 to 5 scale to rank the severity of the allegation. If multiple allegations are made in a report, the severity rating is based on the most sever allegation. For Level 1 cases, these are classified as People & Culture related matters and are solely handled by People & Culture. These types of allegations include interpersonal relationships, issues related to management and other non-Code of Business Conduct violations. Level 2 cases include People & Culture allegations with a legal implication and fraud allegations of an unknown amount. Compliance would partner with People and Culture to investigate these types of matters. Level 3-5 are allegations that are classified as non-People & Culture related matters and can include misconduct by Leadership, allegations involving government or law enforcement, and high dollar fraud exposure. These cases would be typically handled by Compliance or Legal investigators.

A: There are mechanisms in place that restrict access to anyone that is named in the case file. This includes if the allegation names someone in the compliance department that overseas investigations.

A: Compliance reviews the allegation and evaluates who it needs to partner within inside the organization to address the reporter’s concerns. That could include partnering with People & Culture, Quality, Health and Safety and Environment, Finance, Audit and other internal stakeholders. Level 1 cases are referred to People & Culture to investigate.

A: The investigation team may need to meet or interview you to clarify details of the allegation or if new information comes to hand, which needs a response from you. If you have chosen to report anonymously, the investigation team may contact you through the NAVEX system using the Follow Up feature requesting more information.

A: You can talk to the investigations team; however, the investigation is confidential, and you must not discuss the details of it with anyone else at work. You should not speak to other witnesses about the relevant events. This includes investigating the matter yourself. Doing such actions may call into question both your recollection of the events and anyone you speak to. It could lead to the suggestion of collusion, which can undermine the integrity of the investigation. The investigation team is responsible for contacting and speaking to any relevant witnesses. If there are people that you would like to be interviewed during the investigation process, please make sure you tell the investigation team.

A: Subject to confidentiality, the investigation team will communicate the findings of the investigation and that the matter will be closed. The investigation team will provide you as much detail as possible; however, disciplinary action is typically confidential and not disclosed to the reporter. Depending on the severity of the concern and what the review has revealed, outcomes can include disciplinary action or remediation. Disciplinary action can range from training, coaching, written warnings and up to and including termination. Remediation could include additional communication that is provided to employees, additional training, creating or updating a policy and more.

A: You can ask a question through the NAVEX system and receive guidance from Compliance. You can also contact your Legal, Compliance, P&C representatives or discuss with management your concerns. Further, you can always file a report. We would rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you were not sure.

A: When you file a report through the NAVEX website or through the Integrity Helpline, you receive a unique user name and are asked to choose a password. You can return to the NAVEX system again either by internet or telephone and access the original report to answer questions posed by the investigative team and add further information that will help resolve open issues. We strongly suggest that you return to the site in the time specified to answer company questions or provide any additional information which can help the investigative team guide their investigation.

A: Yes, if you don’t have access or are uncomfortable using a computer, you can call your Integrity Helpline toll-free which is available 24 hours a day, 365 days a year.

A: NAVEX 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.

A: All NAVEX correspondences 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).

A: If the telephone number listed above is not functioning, please make your report online through the Integrity Helpline. Please indicate in the report that the telephone number did not work.

A: If there is no service 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.

A: This is a great question. It starts by having a zero-tolerance policy when it comes to retaliation, making sure our employees understand that they will not be retaliated against by anyone in the organization for raising a concern. It is also reading, understanding and living our Code of Business Conduct and policies every day, leading by positive example and creating an environment that encourages other employees to raise integrity concerns early.

A: No, we take a broad approach to allegations of discrimination, harassment and retaliation. Such an allegation does not need to specifically match all the elements included in the jurisdictional criteria to be substantiated. Our Code of Business conduct and our foundational beliefs, including Integrity and Respect, apply regardless of the location of the allegation.

A: We appreciate that you may find this to be a distressing process, regardless of the outcome. If you are a TechnipFMC employee, please know that TechnipFMC has a global Employee Assistance Program, which is a confidential counseling service provided by an external organization, free of charge. More information about the program can be found here.

A: Yes there is. We call it Spotlight on Integrity and its available on POP. We believe that transparency contributes to the health of the organization and ensures that our integrity is never compromised. We support an environment where employees trust and have confidence in the behaviors, decisions and actions of TechnipFMC. One way to ensure trust in the organization is to see how our Compliance program is working by posting our Integrity Helpline statistics for all employees to view. Under the Compliance POP page, you can find this initiative which includes the numbers of reported cases that are substantiated, how many cases are reported anonymously, investigations by region and category.

A: Each quarter Compliance presents allegation data to the Board of Directors, the Audit Committee, leadership from Each Global Business Unit, finance People & Culture and QHSSE. We also present data to our external auditors, PWC.

Compliance reports out on enterprise culture related trends and analysis which includes, opened and closed investigations, substantiation rate, category and severity level breakdown, Key Performance Indicator analysis such as the average days a case was open, root cause and discipline analysis, quarter over quarter comparisons, Region and Global Business Unit analysis, general compliance program updates and review of significant and/or higher severity open matters.

Allegation Management also holds monthly Anticorruption & Fraud meetings with additional members of Compliance, Internal Audit, Security and Finance.

A: Outside of what is mentioned in the prior answer, we also benchmark our Company statistics and trends compared to other companies in our same space to understand where we fit from a broader perspective and areas we need to further hone in on. This is done through analysis of the data provided by NAVEX, Ethisphere and other industry partnerships and resources.