Code of Business Conduct and Ethics Hotline

Home FAQs

Common Questions and Answers for Employees

ABOUT EthicsPoint

What is EthicsPoint?

EthicsPoint 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 EthicsPoint?

  • 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 a 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.

REPORTING – GENERAL

May I report using either the Internet or the telephone?

Yes. With EthicsPoint, you have the ability to file a confidential, anonymous report via either the telephone or the Internet.

What type of situations should I report?

The EthicsPoint system is designed for employees to report potential violations of law or company policies, including the Code of Business conduct and Ethics. You can also use the EthicsPoint system to request guidance about laws and company polices.

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 some behavior you believe violates our Code, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager, or other member of our management team, your local Human Resource representative, or a Thomson Reuters lawyer who supports your business. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances we have partnered with EthicsPoint. We would rather you report here 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. 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 to an 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 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 EthicsPoint 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.

REPORTING SECURITY& CONFIDENTIALITY

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?

EthicsPoint does not generate or maintain any internal connection logs with IP addresses; no information linking your PC to EthicsPoint is available. In fact, EthicsPoint 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 EthicsPoint secure website. Many people choose this option, as EthicsPoint’s data shows that fewer than 12% of reports generated during business hours.

What if I want to be identified with my report?

There is a section in the report where you may identify yourself. If you choose to do so, it will be much easier to conduct a complete and thorough investigation. However, you may also choose to file a report anonymously. Please be aware that local laws, rules or regulations may limit or prohibit anonymous reports or reports concerning particular subjects through the hotline. You will be advised if you work in a country subject to special reporting procedures.

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 identifying information, such as an IP address, so that anonymity is maintained. Plus, EthicsPoint is contractually committed not to pursue a reporter’s identity.

I prefer to report anonymously and I am concerned the information I provide EthicsPoint will ultimately reveal my identity. How can you assure me that will not happen?

The EthicsPoint system is designed to protect your anonymity. 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 toll-free hotline confidential 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 the EthicsPoint’s secure environment. Hotline-based reports have the same security and confidentiality measures applied to them during delivery as Internet-based reports.

Does the telephone toll-free hotline also provide the option to file an anonymous report?

Yes.

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. 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. EthicsPoint 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 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 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.

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, either using the Internet or through EthicsPoint’s Call Center, you receive a unique report key and are asked to select a password. You can return to the EthicsPoint system again either by Internet or telephony 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. This allows you to enter into a dialogue with the company, even if you choose to file an anonymous report, where situations are not only identified, but can also be resolved, no matter how complex.

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

All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity, if you so choose.

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

You can file an EthicsPoint report from any computer that can access the Internet. You can file from home. Many public locations, including most public libraries, have computers with internet access. If you don’t have access or are uncomfortable using a computer, you can call the EthicsPoint toll-free hotline, which is available 24 hours a day, 365 days a year.