Common Questions and Answers

Which company hosts the Valiant Integrity Hotline?

The Integrity Hotline is managed by NAVEX.

What is NAVEX?

NAVEX is a comprehensive and confidential reporting tool to assist management and associates 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 NAVEX?

• We believe that our associates 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 the difference between NAVEX Inc. and EthicsPoint?

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

May I report using either the Internet or the telephone?

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

What type of situations should I report?

The NAVEX system is designed to enable you to raise any violation of our stated Code of Business Ethics & Conduct, or another concern you may have.

If I see a violation, shouldn't I just report it to my manager, Security, or Associate Care and let them deal with it?

As an associate of Valiant, when you observe behavior you believe violates our Code of Business Ethics & Conduct, you have the responsibility to raise it. Ideally, you should raise any concerns forward with your direct manager or other member of our management team. We recognize, however, that there may be circumstances when you are not comfortable raising your concern in this manner. It is for such circumstances we have partnered with NAVEX.

Why should I raise my concern? 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 raise my concern?

We certainly do. In fact, we need you to raise it. 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 to a NAVEX secure server to prevent any possible breach in security. NAVEX makes these concerns available only to specific individuals within the company who are charged with evaluating the concern, based on the type of violation and location of the incident. Each of these recipients has had training in keeping these concerns in the utmost confidence.

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 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.

Can I raise a concern from home and still remain anonymous?

Raising a concern 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 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?

The NAVEX 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 concern. For example, “from my cube next to Jan Smith … ” or “in my 33 years … ”

Is the telephone toll-free hotline 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 concern; the interviewer will type your responses directly into NAVEX’s secure environment. Hotline-based concerns have the same security and confidentiality measures applied to them during delivery as Internet-based concerns.

What if I want to be identified with my concern?

There is a section in the concern where you may identify yourself, if you wish.

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother raising it?

Our company chooses to promote ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all associates, 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 raise 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?

Raise a concern. NAVEX can help you prepare and raise your concern so it can be properly understood. We would rather you raise a concern that turns out to be harmless than let possible 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 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.

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

When you raise a concern, 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 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 regarding my concern?

NAVEX provides functionality that enables company representatives to post questions for you, even if you raise them anonymously. When you receive your report key, you will be provided with the amount of time we expect for the concern 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 concerns as secure as the first one?

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

Can I still raise a concern if I don’t have access to the Internet?

You can raise a concern from any computer that can access the Internet. You can raise 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 NAVEX toll-free hotline which is available 24 hours a day, 365 days a year. Dialing instructions vary by country; verify the proper dialing instructions with a local team member.

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

If the telephone number listed above is not functioning, please raise your concern online through this web site. Please indicate in the concern that the telephone number did not work.

What should I do if the country I am in is not listed above?

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