Compliance Helpline
ATTENTION! This webpage is hosted on NAVEX's secure servers and is not part of the CNH Industrial website or Intranet.

Questions & Answers

"Compliance Helpline" - Commonly Asked Questions

Reporting - General

Reporting Security & Confidentiality

Tips & Best Practices

"Compliance Helpline" - Commonly Asked Questions

What is the CNH Industrial "Compliance Helpline"?

The "Compliance Helpline" is a comprehensive and confidential reporting tool to assist CNH Industrial employees to work together to address questions and concerns regarding the CNH Industrial principles outlined in the "Code of Conduct" or our other corporate policies (including alleged fraud, abuse, and other misconduct in the workplace, all while cultivating a positive work environment) or concerning applicable laws.

Why do we need a system like the "Compliance Helpline"?

  • We believe that our employees are our most important asset. By creating open channels of communication, we can promote a positive work environment and maximize productivity.
  • An effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision-making.

What is NAVEX?

NAVEX is an independent third party service provider that has been retained by CNH Industrial to maintain the "Compliance Helpline" and its case management application.

What is the difference between NAVEX, Inc. and EthicsPoint?

EthicsPoint is the name of the helpline services and case management application owned and operated by NAVEX, Inc.

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Reporting - General

What type of situations should I report?

The "Compliance Helpline," is designed for employees to ask questions and report any concerns pertaining to the principles outlined in the CNH Industrial "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 legal and 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 managers, local Human Resources, local Legal & Compliance Department, 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. It is for such circumstances that we have established the "Compliance Helpline" with the assistance of NAVEX.

May I report using either the Internet or the telephone?

Yes. The "Compliance Helpline" allows you to file a concern or question by identifying yourself or anonymously, subject to applicable local laws and any applicable local company mandates, 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 appropriately. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the assets, goodwill and reputation of an entire company.

Does CNH Industrial 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 NAVEX's secure server to prevent any possible breach in security. Reported concerns are made available by NAVEX only to specific individuals 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 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 NAVEX system concentrates on being a positive aspect of our overall philosophy, and helps us maintain 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 needs while maintaining a positive reporting environment.

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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 PC connects with; won't this log identify me as a report originator?

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

Can I file a concern 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 NAVEX 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.

Please be aware that anonymous reporting may not be permitted in some countries.

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

The NAVEX system is designed to protect your anonymity. 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.

Please be aware that anonymous reporting may not be permitted in some countries.

Is the telephone toll-free helpline confidential and anonymous too?

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's secure environment. Telephone helpline-based reports have the same security and confidentiality measures applied to them during delivery as Internet-based reports.

Please be aware that anonymous reporting may not be permitted in some countries.

Does it help if I identify myself?

Investigating a report is usually faster and more efficient when the CNH Industrial Compliance Team is able to follow up the issue directly with the person who reported it. If you have identified yourself, reasonable efforts will be made 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. CNH Industrial will not tolerate any form of retaliation for reporting a concern in good-faith.

How can I monitor the progress of my concern if I choose to remain anonymous?

Once you have finished reporting your concern, 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 the report, either by visiting the "Compliance Helpline" portal 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 supplied earlier.

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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?

CNH Industrial chooses to promote 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 CNH Industrial'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 can help you prepare and file your concern so it can be properly understood. CNH Industrial 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 boss or other managers are involved in a violation? Won't they get the report and start a cover-up?

The NAVEX 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 "Compliance 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 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 provides functionality that enables CNH Industrial 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 "Compliance 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 Compliance Helpline, which is available 24 hours a day, 365 days a year. International dialing options are available by country on the website.

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