FAQs

What types of concerns can be addressed on the Ethics Hotline?

A wide variety of issues can be addressed including questions about the Code or possible concerns of non-compliance with the Code, policies and company ethical obligations. You can report concerns about:

• Discrimination or harassment
• Workplace violence, threats or bullying
• Conflicts of interest
• Threats, fraud or bribery
• Environmental or safety issues
• Inappropriate gifts or entertainment
• Accounting or financial issues
• Code violations
• Policy violations
• Retaliation
• Other concerning behaviors

Can I remain anonymous?

Anonymity will be maintained within the limits of the law and to the extent it will not impede or hinder the investigative process.

How do I know something will be done with my concern or issue?

No matter who you contact or what resource you choose, your concern will be promptly addressed and handled with the appropriate level of confidentiality. Keep in mind that it may not be appropriate for the results of an investigation to be communicated back to you in light of our obligation to protect privacy and confidentiality, but you will have the ability to know when the review or investigation has been completed and closed.

Who will I be speaking to on the Ethics Hotline?

The Ethics Hotline is staffed by representatives of an independent, third-party vendor called NAVEX.

What is EthicsPoint?

EthicsPoint is a third-party case management tool managed by NAVEX, the vendor that Cox has retained to configure and manage a comprehensive and confidential reporting tool to help us work together in addressing Code of Conduct and Policy related concerns.

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. Having an effective reporting system will supplement our other efforts and allow us to continue to foster a culture of integrity and ethical decision-making.

Can I contact the Ethics Hotline on the Internet as well as via telephone?

Yes, you can file a confidential, anonymous report via telephone or the Internet.

If I am concerned about something, shouldn't I just report it to my manager or HR and let them deal with it?

Ideally, you should bring any concerns forward to your manager or HR. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. We have the Ethics Hotline for these circumstances. Instead of keeping the information to yourself, we would rather you report your concerns anonymously so they can be addressed.

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 you are aware of a concern. By working together, and living the standards set out in our Code, we can stay true to our Cox values and maintain a healthy and productive environment.

Does management really want me to report?

They certainly do. You know what is going on in our company and may have initial knowledge of an activity that may be cause for concern. Management encourages you to report concerns to your manager, HR representative, the Compliance Officer or the Ethics Hotline. By reporting a concern, you can minimize the potential negative impact on our company and people and may help identify issues that can improve company culture and performance.

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPoint secure server to prevent any possible breach in security. EthicsPoint makes these reports available only to specific individuals within the company who are charged with investigating the report, based on the type of violation and location of the incident. Each of these investigators have had training on conducting ethics and compliance related investigations and is aware of our obligation to protect privacy and confidentiality.

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

The Ethics Hotline is designed to protect your anonymity to the extent possible. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the body of the report does not reveal your identity by accident. For example, “From my cube next to Jan Smith…” or “In my 33 years…”

Is the telephone Ethics Hotline confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into EthicsPoint. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the web report for identifying yourself, if you wish. You also have the option of identifying yourself to the specialist on the telephone Ethics Hotline.

What if I remember something important after I file the report, or the company has further questions for me?

When you raise a concern on the Ethics Hotline and choose to remain anonymous, you are encouraged to return to the Ethics Hotline again within the recommended time frame to access the original report and answer follow-up questions that may come up as part of the investigation. You and the company now have entered into an “anonymous dialogue,” where situations are identified and can also be resolved, no matter how complex.

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

Cox chooses to promote ethical behavior – it’s a part of our Cox values. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. So if you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it to your manager, your HR representative, the Compliance Officer or the Ethics Hotline.

Is the Ethics Hotline an example of someone watching over me and my colleagues?

The Code of Conduct and the Ethics Hotline have been developed and implemented to support our company and culture and allows us to assure a safe, secure and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions and/or communicate a concern. Effective communication is critical in today’s workplace, and the Ethics Hotline is a great tool to enhance that communication.

What do I do if I have questions or technology issues while reviewing the Code or utilizing the Ethics Hotline?

Feel free to contact your ethics team or refer to the contacts on the last page of the Code.