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Standards of Business Ethics HelpLine Poster

Frequently Asked Questions

About The Timken HelpLine and EthicsPoint

What is The Timken HelpLine?

At Timken, turning ethics into action means we speak up when something isn’t right. To assist you, we offer a variety of ethics reporting resources. You are encouraged to speak first with a supervisor or manager with whom you feel comfortable. You also may speak with your local organizational advancement/human resources representative. Additionally, the ethics and compliance department is a valuable resource for ethics and compliance training, assistance with resolving ethics issues, and reporting incidents. Please email ethics@timken.com or call 234-262-7025 to contact the ethics office.

We recognize that there may be times when you might be reluctant to discuss concerns or questions with your supervisor or manager. For this and other reasons, the Timken HelpLine is available online and via telephone. The Timken HelpLine is answered and administered by an external company, NAVEX Global.

What is EthicsPoint?

We have hired a third party, NAVEX Global, to accept calls and reports made through The Timken HelpLine. EthicsPoint is owned and operated by NAVEX Global. It 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 The Timken HelpLine?

We believe that our associates are our most important asset. By creating open channels of communication, we can promote a positive work environment and maximize productivity. As a publicly-traded company, we are required by law to have an anonymous reporting vehicle to address accounting and auditing fraud directly to the audit committee. An effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision-making.

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Reporting – General

May I report using either the internet or the telephone?

Yes. With The Timken HelpLine, you can file a confidential report via either the telephone or the internet. In most countries, you may choose to remain anonymous.

What type of situations should I report?

You may report any violation of our code of conduct, the Standards of Business Ethics, or other question or concern you may have. In certain countries, there is a limitation on the type of anonymous reports that may be submitted through The Timken HelpLine. These limitations are disclosed on the reporting form. If you are unable to submit a report through the Timken HelpLine, you may contact the ethics and compliance office to discuss your concern at ethics@timken.com.

If I see a violation, shouldn't I just report it to my manager, security, or human resources/organizational advancement and let them deal with it?

When you observe some behavior that you believe violates our code of conduct, we expect you 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 Global and EthicsPoint to offer The Timken HelpLine reporting system. We would rather you report anonymously than keep the information to yourself.

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 not acting appropriately. 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.

Where do these reports go? Who can access them?

Reports are entered directly on the secure EthicsPoint server hosted by NAVEX Global. These reports are only made available to specific individuals within the company who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports in the utmost confidence.

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

No. The Timken HelpLine is an example of our core value of ethics and integrity in action. Being able to make reports in a confidential and secure manner, 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.

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

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Reporting Security & Confidentiality

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

The EthicsPoint system does not generate or maintain any internal connection logs with IP addresses, so no information linking your company computer to the EthicsPoint server is available. In fact, NAVEX Global is contractually committed not to pursue a reporter’s identity.

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

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 maintained. Plus, NAVEX Global is contractually committed not to pursue a reporter’s identity.

I am concerned that the information I provide to The Timken HelpLine will ultimately reveal my identity. How can you assure me that will not happen?

The Timken HelpLine and EthicsPoint system are designed to protect your confidentiality and anonymity and all reports will remain confidential to the maximum extent possible and consistent with local law.. 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 toll-free HelpLine confidential and anonymous too?

Yes. When you call the toll-free HelpLine, you will be asked to provide the same information that you would provide in an internet-based report. 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 report which allows you to identify yourself.

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Tips & Best Practices

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

Our company chooses to promote 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 seemingly harmless lapse in ethics can have on an otherwise healthy company. So 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. The operators who support The Timken HelpLine at NAVEX Global 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 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 the company has further questions for me concerning my report?

When you file a report online or by telephone, you receive a unique Report Key and are asked to create a password. You can return to the system again either by internet or telephone and access the original report to add more detail or answer questions posed by a company 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 the company now have entered into an “anonymous dialogue” where situations are not only identified but can be resolved, no matter how complex.

Due to the nature of the EthicsPoint system and to help protect confidentiality, your Report Key and password cannot be recovered or re-generated. As a result, it is important that you record them in a secure place and not lose them.

Are these follow-ups on reports as secure as the first one?

All correspondence with The Timken HelpLine and through the EthicsPoint system is held in the same strict confidence as the initial report.

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

You can file a report from any computer that can access the internet. You can file from home. Many public locations, including the public library, have internet computers. If you don’t have access or are uncomfortable using a computer, you can call The Timken HelpLine toll-free hotline 800-846-5363, which is available 24 hours a day, 365 days a year.

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