What is CPKC’s Ethics Line?
CPKC’s Ethics Line is a 24-hours-a-day, 7-days-a-week resource operated by an independent company, NAVEX, to help CPKC respond to your concerns. Ethics Line is an anonymous communication channel available to all CPKC employees and stakeholders to report on matters such as:
If you have knowledge about a violation, or are aware of any other situation that should be reported, you should contact your immediate manager, Human Resources, Legal Services or Internal Audit. However, if the matter involves a violation of a specific CPKC policy, report the matter in accordance with the reporting procedure, if any, set out in the relevant policy. For details on the procedures to be followed for the reporting of violations, refer to CPKC’s Code of Business Ethics link provided on the Home Page.
If the matter relates particularly to workplace harassment, violence, or discrimination, report the matter to Employee Relations at Employee_Relations_Canada@cpkcr.com or Employee_RelationsUS@cpkcr.com or ERMX@cpkcm.mx.
If you do not believe your concern is being addressed, or are not comfortable speaking with one of these contacts, you may report your concerns on an anonymous basis, if desired by using the Ethics Line. Reports can be filed online or by phone and in English, French or Spanish.
Please note that employees who report concerns are protected from retaliation in accordance with CPKC policies. Every effort will be made to maintain the confidentiality of any individual reporting a concern, to the extent permitted by law. It may be necessary to use all the information you disclose to investigate or handle a complaint.
Why do we need the Ethics Line?
At CPKC, we believe in operating ethically in all circumstances and at all times. Employees are required to uphold the highest standards of ethics, integrity and professionalism when performing their duties and responsibilities and when acting as representatives of CPKC. Our commitment to ethical business practice is reflected in CPKC's Code of Business Ethics and throughout our policies.
We are committed to conducting business with integrity, so we ask that you speak up if you are aware of or suspect unethical behavior at CPKC by reporting your concerns anonymously using the Ethics Line. This will enable us to assess the situation and respond appropriately.
In the United States, publicly traded companies are required by law to have an anonymous reporting vehicle to address accounting and auditing fraud directly to the company’s audit committee.
Why has CPKC partnered with NAVEX for reporting your concerns?
NAVEX is an independent company selected by CPKC to provide secure, anonymous telephone and web-based systems for use by CPKC employees and stakeholders who wish to report a concern regarding a potential violation of laws, regulations, CPKC policies, procedures, and Code of Business Ethics, breaches to internal controls, and conflict of interest.
NAVEX’s role is not to address the concern but only to transmit concern details to CPKC to investigate and follow up on the report.
How do I report my concern to the Ethics Line?
The Ethics Line is available 24-hours-a-day, 7-days-a-week and reports can be filed online or by phone and in English or French.
You will have the opportunity to provide your name and contact information, which will assist with follow-up to your concern; however, you can always choose to remain anonymous. If you choose to remain anonymous and/or do not provide sufficient detail, it may affect CPKC’s ability to investigate or complete a comprehensive investigation of the report. The more pinpointed your report is, the greater the ability to quickly investigate and take appropriate action to address your concern.
Please note that the employees who report concerns are protected from retaliation in accordance with CPKC policies. Every effort will be made to maintain the confidentiality of any individual reporting a concern, to the extent permitted by law. It may be necessary to use all the information you disclose to investigate or handle a complaint.
What types of situations should I report?
If you are aware of or suspect unethical behaviour at CPKC, you may report your concerns confidentially using the Ethics Line. You can report allegations and concerns about:
All concerns must be reported in good faith. Reports submitted with a malicious intent or false allegations will not be tolerated.
CPKC employees will be protected from all forms of retaliation, or threats thereof, including in relation to compensation or other terms and conditions of employment, that are directly related to any report by you of a violation, if you: (a) make the report and disclose any information in good faith; (b) reasonably believe it to be substantially true; and (c) do not act maliciously or make false allegations.
If I see a wrongdoing, should I always report it through the Ethics Line?
If you, as an employee, have knowledge about activities that violate, or appear to violate, CPKC's Code of Business Ethics, or are aware of any situation that should be reported, you should contact your manager, Human Resources/Employee Relations, Legal Services, the Office of the Corporate Secretary, or the Internal Audit Department. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. In such circumstances, you may report through the Ethics Line.
Does CPKC really want me to report?
We certainly do. In fact, we need you to report. CPKC takes all complaints made in good faith seriously. You know what is going on in our company - both good and bad. Please do not assume that management is aware of an activity or situation. You may have initial knowledge of an activity that is cause for concern. By raising a concern early, CPKC has the opportunity to address the issue before it becomes a bigger problem. Your reporting can minimize the potential negative impact on the company and our people. In addition, reporting a potential compliance concern may help identify issues that can improve corporate culture and performance.
Please provide as many details as possible when submitting your concern. A pinpointed report increases our ability to quickly investigate and take appropriate actions to address your concern. We encourage you to attach evidence that supports your concern in the form of common file types such as docx, xlsx, email, jpeg, pic, pdf, etc.
Where do these reports go? Who can access them?
Reports are entered directly on NAVEX’s EthicsPoint secure server hosting CPKC’s Ethics Line. NAVEX makes these reports available only to a very few specific individuals within CPKC who are charged with evaluating the report and assigning the report to the appropriate investigator.
Isn’t this system just an example of someone watching over me?
No. NAVEX EthicsPoint is a positive aspect of our overall philosophy that allows us to ensure a safe, secure and ethical workplace. You are encouraged to communicate a concern about wrongdoings. Effective communication is critical in today’s workplace and this is a great tool to enhance that communication.
CPKC employees will be protected from all forms of retaliation, or threats thereof, including in relation to compensation or other terms and conditions of employment, that are directly related to any report by you of a violation, if you: (a) make the report and disclose any information in good faith; (b) reasonably believe it to be substantially true; and (c) do not act maliciously or make false allegations.
What if my supervisor or other managers are involved in a violation? Won’t they get the report and start a cover-up?
No, NAVEX’s EthicsPoint system is designed so that implicated parties are not notified about or granted access to reports in which they are named.
Do I have to disclose my identity while submitting the report?
No. You will have the opportunity to provide your name and contact information, which will assist with follow-up to your concern; however, you can always choose to remain anonymous. If you choose to remain anonymous and/or do not provide sufficient detail it may affect CPKC’s ability to investigate or complete a comprehensive investigation of the report. When an anonymous complaint is received, the CPKC investigator assigned to the report may post questions to ensure they understand the complaint. Remember to return to the system every 2-3 days, with the report key and password provided to you at the time of report submission, to check and respond to the follow-up questions we may have posted.
All concerns, anonymous or non-anonymous, are handled and investigated confidentially to the greatest extent possible. Employees who report concerns in good faith are protected from retaliation in accordance with CPKC policies.
What if I remember something about the incident after I file the report?
When you file a report, you will receive a unique report key and be asked to enter a password. With the report key and your password, you can return to the system at any time, by phone or Internet, and access the original report to add more details.
What if you have questions for me concerning my report?
The NAVEX system enables the CPKC investigator assigned to your report to post questions for you, even if you report anonymously. Follow-up questions are usually posted within 2-3 days so please be sure to check back on a regular basis.
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?
The CPKC’s Ethics Line does not maintain any internal connection logs with IP addresses, so no information linking your PC to NAVEX EthicsPoint is available. NAVEX does gather and retain the reporter’s identity in the system if you provide it when you file the report.
Can I file a report from home and still remain anonymous?
A report filed from your home, the office, a neighbor’s computer, or any other Internet portal will remain anonymous. The NAVEX EthicsPoint website does not record Internet addresses so anonymity is always maintained.
Is the toll-free telephone number to report Ethics Line concerns anonymous too?
Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer from NAVEX will type your responses into the EthicsPoint web site. These reports have the same security measures applied to them during delivery as Internet based reports.
Are the follow-ups on Ethics Line reports as secure as the initial report?
Yes. All correspondence is secured in the same manner as the initial report. If you filed an anonymous report, you may remain anonymous if you so choose.
What if I lose my report key or forget the password I created?
To ensure that security is maintained, if you lose your report key or password, you will need to file a new report. To maintain security, there is no mechanism to reset the password or have someone at NAVEX look up any reports filed in the system. However, we recommend that you mention in the new report that it is related to a report you previously submitted. Individuals who are responsible for assigning the investigations can note this in the related reports.
Can I still file a report if I don’t have access to the Internet?
If you do not have access to the Internet at home, you can file a NAVEX EthicsPoint report from any computer that can access the Internet. 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 NAVEX EthicsPoint toll-free hotline, which is available 24-hours-a-day, 7-days-a-week at: 1-888-279-6235 (Canada and U.S.) and +52 01 800 777 0424 (Mexico)