Frequently Asked Questions
About EthicsPoint
What is EthicsPoint?
- EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX to assist management and employees to work together in addressing fraud, abuse, and other misconduct in the workplace, all while cultivating a positive work environment.
Why do we need a system like EthicsPoint?
- We believe that our employees are our most important asset. By creating open channels of communication, we can promote a positive work environment and maximize productivity.
- Publicly traded companies are required by law to have an anonymous reporting vehicle to address accounting and auditing fraud, that gets sent directly to the audit committee. An effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision-making.
About the Speak Up Hotline
What is the NVIDIA Speak Up Hotline?
- The NVIDIA Speak Up Hotline is a channel for employees, customers, vendors, or clients to raise concerns if they see, hear or suspect something isn’t quite right and/or goes against Our Code. The Speak Up Hotline is open 24/7, with the option to submit inquiries by phone, online, or via the mobile QR code.
Why is the NVIDIA Speak Up Hotline important?
- The NVIDIA Speak Up Hotline is important because integrity, fairness and accountability are the cornerstone of everything we do. NVIDIA’s Code is our shared commitment to preserve and build upon these values, to maintain exceptional relationships with each other, our customers, shareholders, and our communities. It is the foundation of what it means to be an NVIDIAN.
- The NVIDIA Speak Up Hotline provides an easy way for you to get in touch with us if you see, hear or suspect that something isn’t right in your interactions with customers, vendors, clients or another employee. There is no retaliation for raising a possible concern and you may choose to remain anonymous in most cases (unless otherwise required by law in your location).
If I raise a concern, should I be worried about retaliation?
- No. At NVIDIA, we count on our employees to be our eyes and ears. You don’t need to worry about speaking up to share a concern. Our Code strictly prohibits intimidation or retaliation against anyone who contacts us in good faith to share a potential or actual violation of Our Code, or anyone who assists us in looking into an inquiry. If you are ever concerned about possible retaliatory action, report it immediately to your manager, HR, or the Speak Up Hotline.
If I raise a concern, will my manager, teammates and other employees find out?
- When you share a concern with us, we are committed to handling the matter discreetly. We will only involve those necessary to review and/or remediate the matter. In some instances, you may choose to remain anonymous when reporting a concern, however, you should keep in mind that you cannot be retaliated against for contacting us in good faith to share a concern.
Reporting – General
How do I raise a concern through the NVIDIA Speak Up Hotline?
- You can raise a concern by phone, online, or mobile. If calling by phone, a third-party team member will speak with you to understand your concern. If reporting online or via the mobile QR code, you can expect to hear from someone within two business days.
Can I remain anonymous?
- In most cases you have the ability to file a confidential, anonymous report (unless otherwise required by law in your location). If you choose to remain anonymous, please provide as much detailed information as possible so a thorough review of the concern can take place. If you choose to remain anonymous, we will interact with you through the tool as needed and it will not affect the quality of the investigation.
What are some examples of the types of concerns I should report?
- Contact the NVIDIA Speak Up Hotline if:
- You or someone else has been subjected to unfair treatment, bullying, harassment, discrimination, or a violation of policy/law; and/or
- Something was said in the workplace that makes you feel uncomfortable (e.g., a comment about something in the media, a protected class, politics, etc.).
- You have witnessed or have information that someone at NVIDIA may have done something that violates Our Code
What are the channels I can use to report a concern?
- If you observe behavior that you believe violates Our Code, you can report it to your direct manager, management team, your HRBP, NVIDIA-Compliance@nvidia.com and/or the Speak Up Hotline.
Do I have to report an NVIDIA Policy violation?
- 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.
If I see a violation, shouldn't I just report it to my manager, security, or HR and let them deal with it?
- When you observe behavior that you believe violates Our Code, it’s important to report it. Ideally, you should bring any concerns forward to your direct manager or other member of our management team. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that we have partnered with NAVEX. We would rather you report anonymously than keep the information to yourself.
I am aware of some individuals acting unethically, but it doesn't affect me. Why should I bother reporting it?
- Our company promotes ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. You only have to consider what happened in recent corporate scandals 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, consider it your duty to yourself and your coworkers 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?
- File a report. NAVEX 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 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.
How does my report help NVIDIA?
- We want to know where there may be issues so we can address them. When you raise a concern, your input may help us identify issues that can improve our culture and work environment.
- Why should I report? What’s in it for 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, we can maintain a healthy, productive environment and company.
- Does management really want me to report?
- Absolutely. In fact, we need you to report. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the company and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.
Where do reports go? Who can access them?
- When you contact the Speak Up Hotline, a report is entered directly into an independent third-party secure system to prevent any possible breach in security. The report is then made available only to an investigations team member at NVIDIA who investigates, based on the type of violation and location of the incident. The team member has had training in keeping these reports in the utmost confidence.
Who reviews a concern?
- An investigations team member who has had extensive training on Our Code and how to resolve reported issues will be assigned to each reported concern. They will thoroughly review the concern, only discreetly involving those parties necessary to bring it to resolution.
If I am contacted about a concern that someone else reported, do I have to answer questions and/or provide information, if I am asked to do so?
- Yes. If someone else has contacted the Speak Up Hotline with a concern, and you might have information about this concern, you are required to participate as necessary as we thoroughly look into the concern.
What are the possible outcomes after a concern has been thoroughly reviewed?
- Depending on the severity of the concern and what the review has revealed, outcomes can range from no action, to education and coaching, to disciplinary action up to and including termination.
What if I remember something important about the incident after I report my concern? Or what if NVIDIA has further questions for me about my report?
- When you contact the Speak Up Hotline you receive a unique username and are asked to choose a password. You can then return to the Hotline system, access the original report, and add more detail/answer follow-up questions posed. You will be provided guidance on timing to return to the system to answer questions.
Are follow-up questions on reports secure?
- Yes. All contact is held in the same strict confidence as the initial report, continuing under the umbrella of anonymity if you choose to do so (unless otherwise required by law in your location).
Reporting Security & Confidentiality
It is my understanding that the company monitors all activity on company computers. Does this mean if I raise a concern from my work computer, I’ll easily be identified as someone who made a report?
- All Speak Up Hotline reports go to a third-party 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, or through the mobile connection. It is not unusual to report a concern after business hours.
Can I raise a concern from home and still choose to remain anonymous?
- A report from home, a friend’s computer, or any internet or mobile portal will remain secure and you have the option to remain anonymous (unless otherwise required by law in your location).
Is the telephone toll-free hotline confidential and anonymous too?
- Yes. You will be asked to provide the same information that you would provide in an internet or mobile-based report and an interviewer will type your responses into the system. These reports have the same security and confidentiality measures applied to them as internet and mobile reports, and you may choose to remain anonymous (unless otherwise required by law in your location).
What if I want to be identified with my report?
- Most employees that report concerns do identify themselves. This is helpful to gain useful information, identify witnesses and have additional detailed interviews to fully review a concern.