EthicsPoint is an independent company that provides secure, confidential telephone and web-based systems for use by those who wish to report a concern regarding business conduct. Your company is one of many that contracts with EthicsPoint for this service in the belief that potential reporters will be more comfortable reporting a concern if they know they will be reporting to an independent third-party. In addition to providing service 24 hours a day, EthicsPoint offers translation services that allow telephone and web reports to be submitted in dozens of languages.
EthicsPoint's principal responsibilities are:
— Provide confidential telephone and web-based options for reporters to submit concerns about business conduct;
— Protect the identity of reporters who wish to remain anonymous;
— Provide translation services for those reporters who wish to report in languages other than English;
— Transmit information about the concern to designated resources within your company responsible for ethics and compliance so an appropriate investigation can be conducted; and
— Enable communication between an anonymous reporter and the company by serving as an intermediary which can relay follow-up questions and answers, as well as information about the resolution of the case.
It is not EthicsPoint's role to take action to address the concern, only to transmit the concern to the appropriate designees.
Concerns about an immediate threat of physical harm or damage to property should not be reported to EthicsPoint. If you require emergency assistance, please contact your local emergency services.
First, consider whether you are comfortable raising your concern directly, such as to your manager, your manager’s supervisor, or to someone else in your department. Individuals within a company have indicated that, while sometimes challenging, directly addressing issues and or concerns with those involved can be very effective. If you are uncomfortable reporting your concern, do not know whom to contact, believe your concern has not been satisfactorily addressed, or wish to remain anonymous, please proceed with filing a report through EthicsPoint.
If you wish to report a business conduct concern, you may complete a report on this website, or you may speak with a specialist in EthicsPoint's Contact Center, which answers calls to the specially-designated hotline maintained by the company. Regardless of which option you select, you will have the option to remain anonymous, if you so choose. The number you should use to contact the telephone hotline can vary by country. In most cases, the company offers a telephone number you can call with no cost to you. Note the hotline may initially be answered in English. The specialist who answers your call will arrange for fluency in your native language if you would prefer to report your concern in a language other than English. Contact Center Specialists are available 24 hours a day.
If you choose to identify yourself in reporting your concern, the company will make every reasonable effort to hold your name in confidence during the investigation. Many investigations can be more quickly and effectively completed when the reporter is identified because it allows company investigators to follow up directly with the reporter.
In all countries except those that prohibit anonymous reporting, you may report your concern anonymously by using either the web-based form or the telephone hotline, both of which are operated by EthicsPoint. When you complete the report submission process, you will be provided with a report key and asked to create a password. Retain these to follow up on the report you submitted.
When you check back, you can monitor the progress on your concern and add additional information, if necessary. This will also allow the company to ask follow-up questions, while protecting your anonymity if applicable.
If you choose to report anonymously, please take care not to report information that may personally identify you, such as your reporting relationship to others in the company or your physical work location.
EthicsPoint does not trace phone calls or use functionality such as Caller ID. In addition, EthicsPoint does not generate or maintain Internet connection logs containing Internet Protocol (IP) addresses; no information linking you or your computer to EthicsPoint would be available if you choose to make a report. Reports from a computer would come through a secure Internet portal that does not trace or pass along any other information, such as user screen names or the like.
At the end of your report, you will be provided with a report key and asked to create a password. With those two pieces of identification, you can follow up on the report by visiting the EthicsPoint Internet portal or contacting the company hotline. You may need to wait several days after you make your initial report, at which point you can monitor progress on your report and learn whether any additional information is needed from you to address your concern.
Because of the high level of confidentiality that is maintained for reports, if you lose your report key or password, you will be required to file a new report. You can mention in the new report that this matter relates to another report you supplied earlier.
EthicsPoint notifies designated company representatives when a concern is received. As appropriate, the company then commences an appropriate investigation, using internal or external resources with expertise in conducting investigations. The information in your report is shared with appropriate investigation team members, and the concern is investigated promptly and discreetly.
Reports are entered directly on EthicsPoint’s secure servers to prevent any possible breach in security. EthicsPoint makes these reports available only to specific individuals within the company who are charged with evaluating the type of violation and location of the incident and ensuring that an appropriate investigation is conducted. Individuals receiving these report recipients have had training in keeping these reports in the utmost confidence.
The company strictly forbids any retaliation against any person who reports a concern. Complaints made in good faith will not expose you to any sanctions, regardless of whether the underlying facts prove to be correct or result in any corrective action. If you believe you have faced retaliation of any kind, please report it so that the company can investigate.
They certainly do. In fact, they need you to report. Your willingness to report a problem or concern translates into an opportunity for the company to be better. Reporting a concern can minimize the potential negative impact on the company and our customers, and, most importantly, help to alleviate a difficulty you might be facing. Also, offering input may help identify issues that can improve corporate culture and the company’s overall performance. If you observe or suspect a violation of company policy or of the law, as an employee, you have the obligation to speak up. Please do not assume that someone else is going to raise the concern. Unless you speak up, the company may not have the chance to investigate and address the situation.
We take corporate governance matters very seriously. To find out more about our corporate governance practices, please visit the Corporate Governance Webpage on our company website. Here you will find our Sustainability Strategy and information about the members of our Board of Directors and the structure of our Board.
If you are ever in doubt about how to handle yourself in any given situation, ask yourself the following questions to help you decide which path to take:
— Is my action consistent with the Company’s Values and Expected Behaviors?
— Is my action consistent with approved Company policies or practices?
— Does my action conform to the spirit of this Code of Business Conduct and comply with the law?
— Could my action be perceived as improper?
— Would I want to hear or read about my actions in the news?
— Would I want my friends or family to know about my actions?