HBI Resource Line

Common Questions

About NAVEX Global

About Reporting

Security & Confidentiality

Tips & Best Practices

About NAVEX Global

What is NAVEX Global?

NAVEX Global is a comprehensive and confidential reporting tool to assist management and employees to work together to address concerns and/or violations of our Global Code of Conduct, our policies, the law, or other misconduct in the workplace, all while cultivating a positive work environment.

Why do we need a system like NAVEX Global?

  • 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.
  • Publicly traded companies 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 strong culture of integrity and ethical decision-making.

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

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

About Reporting

May I report using either the internet or the telephone?

Yes. With NAVEX Global, you have the ability to file a report by internet or telephone. You can file an NAVEX Global report from any computer that can access the internet. You can file from home. Many public locations, including most public libraries, have internet computers.

What type of situations should I report?

The NAVEX Global system is designed for employees to report violation(s) of our Global Code of Conduct, our policies, the law, or other misconduct in the workplace.

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

When you observe behavior you believe violates our Global Code of Conduct, our policies or the law, you should report it. Ideally, you should bring any concerns forward to your direct manager or other member of our management team.

Why should I report what I know? What's in it for me?

We all have the right to work in a positive environment. 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.

Does management really want me to report?

We certainly do. 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 our culture and performance.

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. 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?

The NAVEX Global system concentrates on being a positive aspect of our overall philosophy, and allows us to ensure 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.

Security & Confidentiality

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

Yes. If you don't have access to a computer or are uncomfortable using a computer, you can call the Resource Line which is available 24 hours a day, 365 days a year.

What should I do if the telephone number is not working?

If the telephone number is not functioning, please make your report online through this web site. Please indicate in the report that the telephone number did not work.

What should I do if the country I am in is not listed with a resource line number?

If there is no service for your location, please make your report online through this web site. Please indicate in the report that dialing instructions for the country you are located in were not available.

It is my understanding that any report 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 Global does not generate or maintain any internal connection logs with IP addresses; no information linking your PC to NAVEX Global 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 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 Global secure website. 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, where permitted by local laws. An internet portal never identifies a visitor by screen name and the NAVEX Global system strips away identifying information, such as an IP address, so that anonymity is maintained. Plus, NAVEX Global is contractually committed not to pursue a reporter's identity.

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

The NAVEX Global system is designed to protect you. In fact, we are 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. For example, "from my cube next to Jan Smith … " or "in my 33 years … "

Is the telephone resource line confidential and anonymous too?

Yes – so long as anonymous reporting is permitted by local laws. 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 Global's secure environment. Telephone-based reports have the same security and confidentiality measures applied to them during delivery as internet-based reports.

What if I want to be identified with my report?

There is a section in the report where you may identify yourself.

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. 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.

I am not sure if what I have observed or heard is a violation of our Code of Conduct, company policy or involves unethical or unlawful conduct, but it just does not look right to me. What should I do?

File a report. NAVEX Global can help you prepare and file your report so it can be properly understood. We 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 Global system and report distribution protocols are designed so reported parties are not notified about 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?

When you file a report, either using the internet or through NAVEX Global’s 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 Global 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 Global provides functionality that enables company representatives to post questions for you, even if the report is made 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.

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

All NAVEX Global correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity, if you so choose (and where permitted by local laws).

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