How do I report integrity or ethical concerns?

It is important to promptly report any situation which may violate the law or Company policy – whether you are involved in the situation or not. It is generally advised that you first report a suspected violation to your supervisor. If this is not a viable option, report it to your supervisor’s manager, local Human Resources department, Legal department, or the Ethics Line.

You may also mail a letter to Crocs, Inc. (Attn: Legal department), 7477 East Dry Creek Parkway Niwot, CO 80503.

We encourage you to provide full information and your name in order to facilitate a complete investigation. We may not be able to investigate some matters, such as allegations of sexual harassment, without such information. Do not, however, investigate a situation on your own. Investigations may involve complex legal issues and acting on one’s own may compromise the integrity of the investigation or adversely affect Crocs and the employee.

What is the Ethics Line?

The Ethics Line is an on-line portal for reporting integrity and ethical concerns. The Ethics Line is staffed by a live operator from an independent company (NAVEX Global), 24 hours a day, 7 days a week. NAVEX Global is a leading provider of corporate ethics and compliance programs and hotlines worldwide, and manages the Ethics Line to ensure independence and objectivity.

Calls or web-based reports are free, confidential and may be made anonymously. Operators are equipped to take these calls and web-based reports in all primary languages of the countries in which we operate or do business. The operator or reporter will relay the information to Crocs’ Compliance office, and will provide you with a case number and call back date if desired.

What type of issues should be reported?

Crocs is committed to maintaining a positive, productive and ethical work environment. To this end, report any concerns, violations or suspicions of any of the following:

  • Accounting, Auditing and Financial Reporting
  • Business Integrity
  • Environment, Health and Safety
  • Fraud & Theft
  • HR, Diversity and Workplace Respect

Should I be nervous that filing a report might have negative consequences for me?

No. Retaliation in any form against anyone who reports, in good faith, concerns or possible violations of the Code, Company policy, or the law, even if the report is mistaken, or who assists in the investigation of a suspected violation, is absolutely prohibited. If you have any concerns that you have been retaliated against, immediately contact your local Human Resource department of the Legal department.

What happens once I file a report?

Reports are referred to the Human Resources, Risk, or Legal departments depending upon the nature and subject matter of the complaint, potential legal implications, or the individual(s) involved. Ethical or legal issues, complaints raising concerns about accounting practices, internal controls, and auditing matters, or violations of the Code are referred to designated members of the Human Resources, Finance, and Law departments. Administrative issues (e.g. lost paychecks), compensation (e.g., salary, bonus, or overtime), e-mail abuse, poor management, and misconduct (e.g., discrimination, harassment, falsification of company records, or theft) are referred to the Human Resources and/or Risk departments. When appropriate, Crocs will provide the employee with the status of the investigation and the outcome.

Management, in consultation with the Human Resources and/or Law departments, will take appropriate corrective action, up to and including termination of employment, in connection with a violation of the Code. Conduct that may result in disciplinary action, up to and including termination, includes: (i) violation of the Code, Company policy, or the law, including requesting others to do so; (ii) failure to report a suspected violation of Company policy; (iii) failure to effectively monitor compliance with Company policies and applicable law by subordinates; (iv) failure to cooperate in an investigation; or (v) retaliation against an employee who makes a complaint or cooperates in an investigation.

Your report is taken seriously. In fact, the Legal department provides the Audit Committee of Crocs’ Board of Directors with quarterly reports on Ethics Line activities and investigations.

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