Frequently Asked Questions

NAVEX is an independent company that provides secure, confidential telephone and web-based systems for use by those who wish to report a concern regarding business conduct. We are one of many companies that contracts with NAVEX for this service in the belief that potential individuals will be more comfortable reporting a concern if they know they will be reporting to an independent third-party.

NAVEX's principal responsibilities are to:

• Provide confidential telephone and web-based options for employees and others to report compliance questions and/or concerns, including potential Company policy violations.
• Transmit information about the concern to the Company to conduct an appropriate investigation.
• Allow a reporter to anonymously communicate with Company investigators by serving as an intermediary which can relay follow-up questions and answers, as well as information about the resolution of the case.
• It is not NAVEX's role to take action to address the concern but only to transmit the concern to the Company.

Due to the confidential nature and high level of security that is maintained for these reports, if you lose your Report Key or Password, you will need to fill out a new report. When filing the new report, you should mention that it is related to a report you previously filed.

The Anonymous Reporting Hotline is hosted by a third party, NAVEX, and uses its confidential call center or secure internet site to receive your questions and reports. You may use the Anonymous Reporting Hotline to Ask a Question, to file a report, or follow up on a prior report. Whether you call or log on, you will be given instructions on how to complete your task. When filing a report, you will be asked to provide as much detailed information as possible. You may also attach a document(s). Your report will be logged and routed to the Company for follow-up.

Reports are entered directly on the NAVEX secure server to prevent any possible breach in security. NAVEX makes these reports available to the Company to review and oversee the investigation process.

NAVEX notifies the Company when a report is received. A determination is made whether an investigation is necessary and if sufficient information has been provided. If needed, a request for additional information from the reporter will be made. Once the report is filed, The Company reviews the details and involves the appropriate team (i.e., Compliance, HR and/or Legal) to conduct the investigation. The concern is investigated promptly and confidentially.

You have an obligation to report behavior that you believe actually or potentially violates Company policy, the Code of Ethics, or the Law. You may report such concerns to your manager, your manager’s manager, or the Compliance, Human Resources or Legal departments. If you are uncomfortable reporting your concern, do not know whom to contact, believe your concern has not been satisfactorily addressed, or if you wish to remain anonymous, please proceed with filing your report through NAVEX.

It is usually easier to conduct a more complete investigation if you identify yourself and those involved because it allows the Company investigator to directly follow-up with you and others. If you choose to identify yourself in reporting your concern, the Company will make every reasonable effort to hold your name in confidence during the investigation.

You may report your concern anonymously—online or by phone—which are operated by NAVEX. If you choose to file your report anonymously, you will be provided with a Report Key and asked to create a Password.
You will need to retain the Report Key and Password to the report you previously submitted. When following up on your report, you can add additional information if necessary or inquire about status. This also allows the Company to ask follow-up questions, while protecting your anonymity. Keep in mind that follow up is important for anonymous reports since we have no other means to communicate with you.

NAVEX does not trace phone calls or use Caller Identification. In addition, NAVEX does not generate or maintain internal connection logs containing Internet Protocol (IP) addresses, so no information linking your computer to NAVEX would be available if you choose to make a report online. Reports from your computer would come through a secure Internet portal which does not trace or show user screen names.

The Company strictly prohibits retaliatory acts, such as demotion, harassment or other negative acts, against any person for reporting concerns or suspected violations in good faith. Reporting in “good faith” means providing all the information you have and that you believe to be truthful. If you believe you have faced retaliation of any kind, please report it so that the Company can investigate.

Concerns about an immediate threat of physical harm or damage to a person or property should not be reported to NAVEX. If you require emergency assistance, please contact your local emergency services.