Follow Up

• At Air Products, integrity is a core value. Thanks to the personal and professional integrity of our employees, Air Products maintains an outstanding reputation for upholding the highest standard of ethical behavior. In today’s fast-paced, globally connected business environment, that’s important to all of our stakeholders and critical to our success.
• It is the responsibility of all Air Products employees’, contractors, vendors/suppliers, and other business partners to report suspected or actual violations to our Code of Conduct. Air Products has a well-defined investigation process that it follows and when appropriate takes corrective action based on the facts of the investigative findings .When we learn of potential illegal or unethical behavior, we will investigate these concerns in a confidential and independent fashion. You are upholding our culture and protecting our stockholder’s investment by speaking up when you become aware and report such behavior.

**Any situations involving imminent threat of personal harm should be reported to Air Products Security Operations Center at 610-481-7955 or 1-800-523-9374 (United States only), local law enforcement, or other emergency services as appropriate under the circumstances**

• We investigate good-faith, fact-based and credible allegations of misconduct. Allegations must be based on a true concern that there is a violation of Air Products’ Code of Conduct, related policies, or the law. Allegations should not be based on insinuations, mere speculation, or gossip.

• Even good faith reports must be made confidentially and through the authorized means described in our Code of Conduct. This is to protect the integrity of the process and the reputations of the accused and others involved in the investigation, each of whom is entitled to be treated with fairness, dignity, and respect. Please note that is therefore not appropriate to widely disseminate allegations internally or externally via broadcast emails or other disruptive means.

• The reporting process must not be used for inappropriate purposes, such as false reporting designed to harass, slander or humiliate someone. Employees who knowingly make false reports or who misuse the reporting process for inappropriate purposes or by using inappropriate means will be subject to potential discipline, up to and including termination of employment and, when appropriate, referral to local law enforcement authorities. Assigned workers and/or third parties who knowingly make false reports or misuse the reporting process for inappropriate purposes or by using inappropriate means are subject to being denied access to Air Products’ facilities, personnel and assets, and permission to perform services on Air Products’ behalf.
• However, any individual who makes a good faith report of suspected misconduct (i.e., a report that he or she reasonably believes to be true) will not be subject to discipline or other consequences even if the underlying concern turns out to be unfounded or could not be substantiated after investigation.

• To protect the integrity of internal investigations and the reputation and privacy of those involved, all internal investigations must be conducted confidentially. Air Products personnel conducting investigations will not disclose the fact or subject of, any details relating to, or the identities of accused individuals or other involved persons, except to those with a legitimate need to know. All accused individuals and others involved in internal investigations must be treated fairly and with dignity and respect, in accordance with applicable law and in consultation with authorized workers’ representatives (where applicable). Due to confidentiality, privacy and other considerations, we may not be able to advise you of the results of an inquiry resulting from your report. However, please remember that our inability to do so does not mean we didn’t investigate and take appropriate action.

• DO: Report good faith, fact-based claims of misconduct in a professional manner through appropriate means. You may do so anonymously where consistent with local law but remember that our confidential process and Non-Retaliation Policy protect you if you decide to come forward in person.
• DON’T: Send broadcast emails (anonymous or otherwise) complaining of misconduct to a wide group of employees.
• DON’T: Use the reporting process to cause disruption or harass someone.
• DON’T: Investigate potential misconduct yourself. If you have any questions on how to proceed, reach out to your manager, HR Representative, or Corporate Security and Investigations for guidance.

Yes. You have the ability to file a report via either the telephone or the Internet.

While the issues you can report may be limited by regulations in your country, the IntegrityLine system is designed for employees to report any violation of our stated Code of Conduct, or another concern you may have.

Reports are entered directly into a secure server to prevent any possible breach in security. These reports are available only to specific individuals within Air Products 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.

Yes. All reports received through the IntegrityLine system is treated in a confidential manner.

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 system strips away identifying information, such as an IP address, so that anonymity is maintained. Plus, our supplier, NAVEX, is contractually committed not to pursue a reporter’s identity.

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 the IntegrityLine System. Hotline-based reports have the same security and confidentiality measures applied to them during delivery as Internet-based reports.

No. The IntegrityLine 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.

When you file a report, either using the Internet or through NAVEX’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 IntegrityLine system again, either by Internet or telephone, and access the original report. At that point, you can add more details.

All 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).

EthicsPoint is a comprehensive and confidential reporting tool owned by NAVEX and utilized by Air Products 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.

• We believe that our employees are our most important asset. By creating open channels of communication, we can promote a positive work environment.
• 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 culture of integrity and ethical decision-making.