Ethics Helpline – Frequently Asked Questions

FAQ – General

What is the American Express Global Business Travel (GBT) Ethics Helpline?

The GBT Ethics Helpline is a comprehensive and confidential reporting tool to help GBT employees work together to address questions and concerns regarding the principles outlined in the Code of Conduct, other corporate policies or applicable laws.

The GBT Ethics Helpline will provide an opportunity for employees to confidentially, or, if desired, anonymously, seek assistance or file a report about a concern or incident regarding ethical or compliance matters, including unlawful activity such as fraud or accounting issues; policy violations such as favoritism or T&E issues; questionable conduct such as employment discrimination or harassment; health, safety and security matters; potential corruption issues, sanctions violations, conflicts of interest, vendor concerns or improper bidding processes; or other suspected impropriety. Employees may also use the GBT Ethics Helpline to seek advice or submit a question regarding ethical issues or company policy, law or regulations and provide feedback or suggestions on areas we can improve as a company. The GBT Ethics Helpline will be confidential, easy to use and accessible any time via phone or online.

Why do we need a system like the GBT Ethics Helpline?
  • We believe that our employees are our most important asset. By creating open channels of communication, we can promote a positive work environment, foster a safe, secure and ethical workplace throughout our company and maximize productivity.
  • An effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision-making.
Will the GBT Ethics Helpline be available for all GBT employees?

Initially, the Ethics Helpline will launch globally with a web-based platform (English language) and global telephony lines, followed by other website translations as they become available in July/August 2015.

What is EthicsPoint?

EthicsPoint is the name of the helpline services and case management application owned and operated by NAVEX, Inc., an independent third-party service provider that has been retained by GBT to maintain the GBT Ethics Helpline and our case management application.

Reporting – General

What type of situations should I report?

The GBT Ethics Helpline is designed for employees to ask questions and report any concerns pertaining to the principles outlined in the GBT Code of Conduct, our other corporate policies or applicable laws.

If I see a violation, shouldn't I just report it to my manager, Human Resources, or Compliance, and let them deal with it?

When you observe behavior you believe may violate the principles contained in the Code of Conduct, our other corporate policies or applicable law, we encourage you to report it. Ideally, you should bring any questions or concerns forward to your direct leader, Employees Relations, Human Resources, Compliance, or as otherwise provided under local reporting procedures. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. These types of circumstances are why we have established the GBT Ethics Helpline.

May I report using either the Internet or the telephone?

Yes. The GBT Ethics Helpline allows you to file a concern or seek advice by identifying yourself or anonymously, subject to applicable local laws and any applicable local company mandates (Spain is the only country where anonymity is not allowed), via either the telephone or the Internet.

Why should I report what I know?

We all have the right to work in a positive environment. With this right comes the responsibility of acting in an ethical manner and letting the appropriate people know if you believe someone is not acting properly. By working together, we can maintain a safe and healthy and productive environment. Corporate misconduct can threaten the assets, goodwill and reputation of an entire company.

Does GBT really want me to report?

We certainly do. In fact, we encourage you to report your concerns and ask questions. 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 concerns go? Who can access them?

Concerns are entered directly into the EthicsPoint secure server to ensure confidentiality. Reported concerns are made available by EthicsPoint only to specific business users within the company who are charged with evaluating the reports, based on the type of reported concern and location of the incident. Each of these report recipients has had specialized training in keeping these reports confidential to the fullest extent practicable under the circumstances.

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

The GBT Ethics Helpline was developed to be a positive contribution to our company, and helps us maintain a safe, secure, and ethical workplace. You are encouraged to use the system 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.

Reporting Security & Confidentiality

It is my understanding that any concern I send from a company computer generates a server log that shows every website my computer connects with. Won’t this log identify me as a report originator?

NAVEX’s EthicsPoint does not generate or maintain any internal connection logs with IP addresses; no information linking your computer to NAVEX is available when you access the GBT Ethics Helpline. In fact, NAVEX 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 PC outside our work environment (such as one located at an Internet café, the library, a friend’s house, etc.) through the NAVEX EthicsPoint secure website. Many people choose this option, as NAVEX’s data shows that fewer than 12% of reports are generated during business hours.

If I want to remain anonymous, can I file a concern online from home and still remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous, if that is how you choose to make your report. An Internet portal never identifies a visitor by screen name, and the NAVEX EthicsPoint system strips away identifying information, such as an IP address, so that anonymity is maintained. Plus, NAVEX is contractually committed not to pursue a reporter’s identity.

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

If you want to remain anonymous, the NAVEX EthicsPoint system is designed to ensure that happens. In fact, NAVEX is contractually committed not to pursue a reporter’s identity. To further ensure your anonymity, you – as a reporting party – need to be careful not reveal any identifying details as part of your report.

Is the telephone helpline confidential?

Yes. You will be asked to provide the same information you would provide in an Internet-based report; the interviewer will type your responses directly into NAVEX EthicsPoint’s secure environment. NAVEX applies the same security and confidentiality measures to telephone-based reports as Internet-based reports when they deliver them to the GBT business users for review.

Does it help if I identify myself?

Investigating a report is usually faster and more efficient when the GBT Compliance team is able to follow up directly with the person who reported the issue. If you have identified yourself, they’ll make reasonable efforts to respect your confidentiality. Your identity will not be disclosed unless necessary for carrying out a proper investigation, required in the course of legal proceedings, or as required by local laws or local company mandates. GBT will not tolerate any form of retaliation for reporting a concern in good faith.

How can I monitor the progress of my concern or follow up on a question if I choose to remain anonymous?

Once you have finished filing your concern or submitting a question, you will be provided with a report key and asked to create a password. With these two pieces of identification, you will be able to follow up on the report or your inquiry, either by visiting the GBT Ethics Helpline portal online or contacting the telephone helpline. You may need to wait a few days after your submission before you can monitor progress and check whether you are being asked for any additional information.

What if I lose my report key or password?

In order to maintain the highest level of confidentiality, you will be asked to file a new concern if you lose either your report key or your password. You should mention that your new report relates to one submitted earlier.

Can I submit supporting documentation when I file a concern?

Submitting copies of any documents that will support your complaint is extremely helpful to our evaluation process. However, please submit copies of documents, rather than originals, as they cannot be returned. If we need the original documents, we will ask for them later.

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?

American Express Global Business Travel promotes ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. One only has to consider what happened in recent corporate scandals to see the disastrous effects a seemingly harmless lapse in ethics can have on an otherwise healthy company. If you know of any incidents of alleged misconduct or ethical violations, consider it your duty to yourself and your co-workers to report it.

I am not sure if what I have observed or heard is a violation of American Express Global Business Travel’s principles, company policy, applicable law or involves unethical conduct, but it just does not look right to me. What should I do?

File a concern. NAVEX EthicsPoint can help you prepare and file your concern so it can be properly understood. American Express Global Business Travel would rather you report a situation that turns out to be harmless than let possibly unethical or illegal behavior go unchecked because you were unsure.

What if my direct leader or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The NAVEX EthicsPoint system and report distribution protocols are designed so implicated parties are not notified about or granted access to reports in which they have been named, unless required by local laws.

What if I remember something important about the incident after I file the concern?

When you file a concern via the GBT Ethics Helpline, either using the Internet or through NAVEX’s telephonic Contact Center, you receive a unique report key and are asked to select a password. With the report key and your password, you can return to the NAVEX EthicsPoint system again, either by Internet or telephone, and access the original report. At that point, you can add more details.

What if you have questions for me concerning my report?

NAVEX EthicsPoint provides functionality that enables American Express Global Business Travel representatives to post questions for you, even if you report anonymously. When you receive your report key, you will be provided with the amount of time we expect for the report to be processed. When that time has passed, we strongly suggest you check to see if any questions have been posted. Providing the opportunity for such dialogue means situations may not only be identified but can also be resolved, no matter how complex.

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

All NAVEX correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity, if you so choose, to the extent permitted by local law and local company mandate.

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

You can file a report via the GBT Ethics Helpline from any computer that can access the Internet. You can file a concern from home. Many public locations, including most public libraries, have Internet computers. If you don’t have access or are uncomfortable using a computer, you can call the Ethics Helpline, which is available 24 hours a day, 365 days a year. International dialing options are available by country on the website.