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Common Questions and Answers for Associates

About EthicsPoint

What is NAVEX?

NAVEX is a comprehensive and confidential reporting tool that operates our JCPLine to assist associates in working 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 for our JCPLine?
  • 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.
  • 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.

Reporting – General

May I report using either the Internet or the telephone?

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

What type of situations should I report?

The JCPLine system is designed for associates to report any violation of our Statement of Business Ethics or company policies, or other concerns you may have.

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 that you believe violates our Statement of Business Ethics, we expect you to report it. You may raise an issue at any level, but we encourage you to start with your manager first. You can also talk to another member of the leadership team or to Human Resources. 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 NAVEX to provide you with this tool for making confidential reports. And if you feel more comfortable doing so, we would rather you report anonymously (where permitted by the laws in your country) 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 acting inappropriately. Corporate misconduct can threaten the livelihood of an entire company, but by working together, we can maintain a healthy and productive environment.

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 associates. Also, offering positive input may help identify issues that can improve our culture and performance.

Where do these reports go? Who can access them?

When you make reports through JCPLine, reports are entered directly to a NAVEX secure server to prevent any possible breach in security. NAVEX makes these confidential reports available only to specific individuals within our company who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these individuals has had training in keeping these reports in the utmost confidence.

Isn’t this system just an example of someone watching over me?

The JCPLine 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?

We hired NAVEX to operate our JCPLine so that our associates could feel more comfortable making reports. NAVEX does not generate or maintain any internal connection logs with IP addresses; no information linking your PC to NAVEX is available. In fact, NAVEX 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 secure website. Many people choose this option, as NAVEX’s data shows that fewer than 12% of reports are 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 the laws in your country. 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 will ultimately reveal my identity. How can you assure me that will not happen?

The JCPLine system, operated by NAVEX, is designed to protect you. In fact, NAVEX is 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 and anonymous too?

Yes – so long as anonymous reporting is permitted by the laws in your country. When you report by telephone, 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’s secure environment. Hotline-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, if you wish.

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 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 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. NAVEX operates JCPLine in a manner that can help you prepare and file your report so it can be properly understood. We would rather you report a concern in good faith 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 NAVEX system and report distribution protocols that operate JCPLine are designed so that 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?

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 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 provides the JCPLine with functionality that enables company representatives to post questions for you, without knowing your identity if you report 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, no matter how complex.

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

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 the laws in your country).

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

You can file a report from any computer that can access the Internet. You can file 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 JCPLine toll-free hotline – available 24 hours a day, 365 days a year. Dialing instructions vary by country and so be sure to verify the proper dialing instructions before placing your call.

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

If the telephone number listed above 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 above?

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.