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What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool to assist management and employees to work together to address fraud, abuse, and other misconduct in the workplace, all while cultivating a positive work environment.

Why do we need a system like EthicsPoint?

We expect and require that our Colleagues will act with the highest possible standards of honesty, ethical conduct, and integrity in all that they do. 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 a suitable reporting vehicle to address accounting and auditing fraud directly to an Audit Committee. Anonymity is available where legally permitted.

An effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision-making.

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May I report using either the Internet or the telephone?

Yes. With EthicsPoint, you have the ability to file a confidential report via either the telephone or the Internet. If you wish to report via the Internet, you may submit a report on this website. If you wish to submit a report over the telephone, you may speak with a Contact Center Intake Specialist by calling the toll-free hotline number listed on the website for the country you select. Regardless of which option you select, you will have the option to remain anonymous, as permitted by local laws.

Note the hotline may initially be answered in English. The Intake 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.

What type of situations should I report?

The EthicsPoint system is designed for employees and other people to report any violation of the Willis Towers Watson Code of Conduct which is outlined in our Code of Conduct and Whistleblower Reporting. Employees and other people can also submit an inquiry or report on any other concern.

If I see a violation, shouldn’t I just report it to my manager, security, or human resources representative?

First, consider whether you are comfortable raising your concern directly to an internal resource, such as to your manager, your manager’s supervisor, or to someone else in your department. Employees are always encouraged to first contact local management to try to resolve concerns before filing a report. Individuals within many companies have indicated that, while sometimes challenging, directly addressing issues and or concerns with those involved can be very effective. However, if you are uncomfortable reporting your concern, do not know whom to contact, or believe your concern has not been satisfactorily addressed, please proceed with filing a report through EthicsPoint.

Why should I report what I know? 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 acting unethically. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the livelihood of an entire company.

Does management really want me to report?

We certainly do. In fact, we need you to report. You know what is going on in our company - both good and bad. 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.

What if I face retaliation?

Willis Towers Watson strictly forbids retaliation against any person for reporting a concern. If you make a complaint in good faith, you will not be punished for making the complaint, regardless of whether the underlying facts prove to be incorrect or result in any corrective action. If you believe you have faced retaliation of any kind, please report it so that Willis Towers Watson can investigate.

Isn’t this system just an example of someone watching over me?

The EthicsPoint system concentrates on being a positive aspect of our overall philosophy, and allows us to assure a safe, secure, and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern. Effective communication is critical in today’s workplace and this is a great tool to enhance that communication and supports our Code of Conduct.

We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment.

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Where do these reports go? Who can access them?

Reports are entered directly to a NAVEX Global secure server to prevent any possible breach in security. NAVEX Global makes these reports available only to specific individuals within the company who are charged with evaluating the report, based on the type of violation and location of the incident. Every report will be treated as highly confidential, consistent with WTW policy.

It is my understanding that any report I send from a company computer generates a server log that shows every web-site that my PC connects with, and won’t this log identify me as a report originator?

EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available. In fact, EthicsPoint is contractually committed to not pursue a reporter’s identity.

If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside your work environment (such as one located at an Internet café, at a friend’s house, etc.) through the EthicsPoint secure website. Many people choose this option, as EthicsPoint’s data shows that fewer than 12% of reports are generated during business hours.

Should I identify myself?

Preferably yes. If you identify yourself in reporting your concern, Willis Towers Watson will make every reasonable effort to hold your name in confidence during the investigation. Many investigations can be completed more effectively and quickly when the reporter is identified because it allows the investigator to follow up directly with the reporter. In some countries, data privacy laws stipulate that implicated parties have a right to know the source of the information in which they are implicated; in those instances, individuals named within a report will have the opportunity to respond to the descriptions of the circumstances you have reported.

May I report my concern anonymously?

In general, it is advisable that you disclose your name when submitting a report so that Willis Towers Watson can complete a more thorough investigation and help resolve your issue. However, you may also choose to remain anonymous. At the conclusion of the reporting process, you will be provided with a Report Key and asked to create a password. You will need to use these to access the report you submitted. We encourage you to check back in order to monitor the progress on your concern and add additional information, if necessary. This also allows Willis Towers Watson to ask follow-up questions, while protecting your anonymity.

If you do choose to report anonymously, please take care not to report information that may personally identify you, such as:

  • Your reporting relationship to others within the company
  • Your exact physical work location

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is totally maintained. Additionally, EthicsPoint is contractually committed to not pursue a reporter’s identity.

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I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?

Willis Towers Watson chooses to promote ethical behavior as per the Code of Conduct. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. You only have to consider what has happened in recent corporate scandals to see the disastrous effects that a seemingly harmless lapse in ethics can have on an otherwise healthy company. If you are aware of any incidents of misconduct or ethical violations, consider it your duty to yourself and your Colleagues 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. EthicsPoint 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 because you weren't sure.

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 process are designed so that implicated parties are not notified or granted access to reports in which they have been named.

What if I remember something important about the incident after I file the report? Or what if Willis Towers Watson has further questions for me concerning my report?

When you file a report at the EthicsPoint Web site or through the EthicsPoint Contact Center, you will receive a unique Report Key and are asked to choose a password. You can return to the EthicsPoint system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a Willis Towers Watson representative and add further information that will help resolve open issues. We strongly suggest that you return to the site in the time specified to answer company questions. You and Willis Towers Watson will enter an “anonymous dialogue” where situations are not only identified but can be resolved, no matter how complex.

What should I do if I lose my Report Key or password?

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.

Are these follow-ups on reports as secure as the initial report?

All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity if you choose.

Can I still file a report if I don’t have access to the Internet?

You can file an EthicsPoint report from any computer that can access the Internet. You can file from home. Many public locations, including the public libraries, have Internet computers. If you don’t have access or are uncomfortable using a computer, you can call EthicsPoint toll-free 24 hours a day, 365 days a year.

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