About EthicsPoint

Reporting – General

Reporting – Security & Confidentiality

Tips & Best Practices


About EthicsPoint

What is EthicsPoint?

EthicsPoint is the platform for our Reportline, and is a helpful and private tool from NAVEX that gives employees and management a way to address issues like fraud, abuse, or misconduct together while fostering a supportive and positive workplace.

Why do we need a system like EthicsPoint?

Our employees are our most important asset. By creating open channels of communication, we promote a positive work environment and maximize productivity.

An effective reporting system augments our other efforts to foster a culture of integrity and ethical decision-making.

Reporting – General

How long does it take to investigate a report?

It depends on the nature of the report, the involved parties, and the associated issue. The more information that's provided during the initial report, the easier it is to investigate and resolve. More complex investigations may take longer.

May I report using either the Internet or the telephone?

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

What types of situations should I report?

You should report any situations that you believe compromise our commitment to integrity and ethical conduct. Here are some examples of the types of concerns you can report through our Ethics Hotline:

While our Ethics Hotline is primarily for ethics and compliance issues, we also understand that HR-related concerns are important. For matters such as workplace disputes, performance issues, or other HR-related concerns, we recommend directing these to your management or leadership internally. However, if you feel uncomfortable doing so or believe the issue has ethical implications, please do not hesitate to report it through this hotline.

Why should I report what I know? What's in it for me?

We all have the right to work in a positive environment and 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.

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 on the EthicsPoint secure server. NAVEX 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 handling these reports confidentially.

Will I find out the result of the investigation?

We understand how important it is to know that your concerns are being addressed, and we want to assure you that every report is taken seriously and handled with care. That said, because of confidentiality considerations, we may not always be able to share the specific results of an investigation with you. However, please know that your report contributes to ensuring a safe, ethical, and positive environment for everyone.

Reporting – Security & Confidentiality

Can I file a report from home and still remain anonymous?

A report from home, a neighbor's computer, or any portal will remain secure and anonymous. An internet portal never identifies a visitor by screen name and the EthicsPoint system strips away internet addresses so that anonymity is totally maintained.

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

The EthicsPoint system protects your anonymity. However, if you wish to remain anonymous, you as a reporting party need to ensure that the body of the report does not reveal your identity by accident. For example, "From my cube next to Alexander Morales…" or "In my 33 years…".

Is the telephone toll-free Reportline confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in an internet-based report and an interviewer will type your responses into the EthicsPoint website. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the report to identify yourself, if you wish. Keep in mind that the more information you provide, the easier it is for our team to investigate.

Tips & Best Practices

I am aware of some individuals acting unethically, but it doesn't affect me. Why should I report it?

Our company cares deeply about maintaining ethical behavior, and reporting unethical conduct is essential for protecting the well-being of everyone here. Even if something doesn't directly affect you, unethical actions at any level can harm the company and all employees over time, including you. Think about how recent corporate scandals have shown the devastating impact of ethical lapses. If you're aware of any misconduct or violations, consider it a responsibility to yourself and your coworkers to report it. It's an important step in keeping our work environment healthy and trustworthy.

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?

Speak with your manager, HR, the Ethics and Compliance team, or file a report. NAVEX can help you prepare and file your report so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked.

What if my leader or other managers are involved in a violation? Won't they get the report?

The EthicsPoint system and report distribution ensure that implicated parties are not notified 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 at the EthicsPoint website or through the EthicsPoint Call Center, you receive a unique, randomized number called a "Report Key" and are asked to choose a password. You can return to the EthicsPoint system again either by internet or telephone and access the original report to add more detail or answer questions posed by a company representative. We strongly suggest that you return to the site in the time specified to answer company questions. You and the company now have entered into an "anonymous dialogue," where situations are not only identified, but can also be resolved, no matter how complex.

In addition, you now have the option of providing your email address for confirmation and communication purposes only, and it will not be shared with the recipients of the report.

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.

What if I lose my Report Key or forget the Password I created?

To ensure that security and confidentiality is maintained, if you lose your report key or password, you will need to file a new report. Mention in the new report that it is related to a report or question you previously submitted.

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 public libraries, have internet computers. If you don't have access to or are uncomfortable using a computer, you can call the EthicsPoint toll-free hotline for your associated location, which is available 24 hours a day, 365 days a year.