EthicsPoint - Parsons Corporation

Reporting Security & Confidentiality

About EthicsPoint

What is EthicsPoint?

EthicsPoint is an independent case management tool and service, hosted, operated and staffed by NAVEX, an independent company. Parsons subscribes to the service to provide a database for ethics case management, and a 24x7, worldwide call center service for ethics inquires or concerns reported by employees, customers and the public. Since NAVEX hosts the service and staffs the call center, inquiries and reports may be anonymous, and no identifying information is recorded or available to Parsons unless the inquirer or reporter chooses to provide identifying information.

Why do we need a system like EthicsPoint?

EthicsPoint provides a tool and service to:

Ask questions and receive guidance in advance to ensure that we do the right things and do things the right way.
Report concerns or challenges to ethics staff, so that they can be investigated and resolved quickly.
Fulfill our requirement as a public company to offer an anonymous reporting vehicle to address accounting and auditing fraud directly to the audit committee.

Reporting – General

May I report using either the Internet or the telephone?

Yes. EthicsPoint enables you to file a confidential, anonymous report, ask a question, make a suggestion or request support via either the telephone or the Internet.

What types of situations should I report in EthicsPoint?

The EthicsPoint system is provided to allow employees, customers and others to ask questions, make suggestions, or report concerns related to integrity and ethics matters, including questions or concerns related to anything covered in our Code of Conduct.

Shouldn't I just report a question or concern to my manager, security, or People and let them deal with it?

The company provides and promotes a number of communication channels to support free and open dialog with employees and others. Ideally, you should bring your question or concerns to your direct manager or other member of our management team. We recognize, however, that there may be situations or circumstances when you’d prefer to ask or report anonymously, or another way. EthicsPoint offers an accessible, open method to complement traditional company provided options. The most important thing is that you bring your question or concern to the company so that it can be addressed.

Why should I report an issue or concern?

Integrity is a core value at Parsons. We want to provide a positive, inclusive and professional work environment and to always conduct our business in accordance with our Core Values and our Code of Conduct. Our program is built upon, and relies upon, our people. By working together, we can maintain a healthy and productive working environment, welcoming for all, and keep Parsons at the forefront of ethical business conduct, where we have been privileged to operate for decades.

What happens when I ask a question or report an issue or concern?

Your question or report to the website or call center opens a case file in EthicsPoint, and a system notification to the Ethics Committee or Employee Relations to review the case and respond to your question or begin an investigation based on the information that you provide in your report. It is important for you to provide as much information in as much detail as possible to promote an efficient and complete investigation. If you identify yourself, the investigator may contact you directly to obtain additional information or detail. If you choose to remain anonymous, we cannot contact you or respond to you directly, and all follow up will be exclusively through EthicsPoint. Inquiries are generally replied to within 2-3 business days. Issues or concerns are normally investigated within 45 calendar days. Ethics inquiries, reports and investigations are treated confidentially, unless disclosure is required by law or to take appropriate corrective action.

Reporting Security & Confidentiality

Does NAVEX generate or maintain a server log that identifies my company or personal computer when I connect to the website to ask a question or report an issue or concern?

No. NAVEX does not generate, maintain or provide connection logs with IP addresses, so no information linking your PC to EthicsPoint is available to Parsons. You may also make an inquiry or file a report from any internet connected device, including public internet cafés, tablets or mobile phones belonging to you or someone else that is not traceable to you.

NAVEX’s Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is totally maintained.

I am concerned that the information I provide to EthicsPoint will reveal my identity. How can you assure me that will not happen?

The EthicsPoint system protects your anonymity, and no system information is traceable back to you. You will not be asked for identifying information other than the location where the question or concern arises, which is necessary to comply with privacy laws. We are only able to respond to questions, or investigate issues or concerns, based on the information that you provide, It is important that you provide enough detail for us to respond or investigate thoroughly. You can assure your anonymity by taking care to avoid including unique, identifying information in your report. For example, if you are the only person who has been with the company for 35 years, rather than saying “I’ve been with the company for 35 years,” which could identify you, you might say, “I’ve been with the company for well over 20 years.”

Is the telephone toll-free hot line confidential and anonymous too?

Yes, if you choose to remain anonymous. Your call will be answered by a NAVEX employee, not a Parsons employee. You will be asked to provide the same information that you would provide on the EthicsPoint website, and the NAVEX interviewer will record your responses into the EthicsPoint Web site. If you choose to remain anonymous, you will not be asked for identifying information other than the location where the question or concern arises, which is necessary to comply with privacy laws.

Can I choose to identify myself with my question or report?

Yes, absolutely, and doing so facilitates communicating with you directly and responding to your question or investigating your concern.

Tips & Best Practices

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?

Make an inquiry or file a report. A proactive inquiry or report can often prevent a question from becoming an issue or concern. Our Ethics program is built upon, and relies upon, everyone working together to do the right thing.

What if my question or concern involves my boss or management team? Will he, she or they know that I inquired or reported a concern?

The EthicsPoint system is limited / controlled access, and is only available to the Ethics Committee and Ethics Officers assigned to respond to an inquiry or investigate a case. Other Managers and employees do not have access to the system or its contents. In addition, the system automatically blocks notifications and access to case files for anyone who is named or implicated in an inquiry or report.

If I ask a question or file a report anonymously, how do I follow up to get an answer or learn what happened?

When you ask a question or file a report on the EthicsPoint Web site or through the EthicsPoint Call Center, you receive a unique, randomized number called a “Report Key” and are asked to choose a password. If you choose to remain anonymous, you are anonymous, and we are only able to communicate with you through the website. It is essential that you return to the site at least once each week to monitor progress of your case, and/or to answer any follow up questions from the Ethics team.

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

To ensure security and confidentiality, your report key and password are unique and cannot be recreated or retrieved. If you lose your report key or password, you will need to create a new inquiry or file a new report. If lose your report key or password and file a new report, please mention that it is related to a report or question you previously submitted so that we link the cases and provide a unified response.