COMMON QUESTIONS AND ANSWERS

ABOUT NAVEX GLOBAL

What is NAVEX Global?
NAVEX Global is a comprehensive and confidential reporting tool used to assist US Foods management and employees 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 Global?
  • US Foods believes that our employees 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 enhance our other efforts to foster a culture of integrity and ethical decision-making.

ABOUT REPORTING

May I report using either the Internet or the telephone?
Yes. With NAVEX Global, you have the ability to file a report via either the Internet or the telephone.
What type of situations should I report?
The NAVEX Global system is designed for individuals to report any violation of the US Foods Code of Conduct, or another concern 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 some behavior you believe violates the US Foods Code of Conduct, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager or other member of your management team. 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 Global. We would rather you report anonymously (where permitted by law) 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 at US Foods. With that right comes the responsibility of acting in an ethical manner and letting the right people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment here at US Foods. Corporate misconduct can threaten the livelihood of an entire company.
Does management really want me to report?
We certainly do. In fact, we need you to report and you have an obligation 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 US Foods and our people.
Where do these reports go? Who can access them?
Reports are entered directly to a NAVEX Global secure server to prevent any possible breach in security. NAVEX Global makes these reports available only to specific individuals within US Foods who evaluate 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.
Isn’t this system just an example of someone watching over me?
The NAVEX Global system concentrates on being a positive aspect of our overall philosophy, and allows us to ensure a safe, secure, and ethical workplace at US Foods. You are encouraged to seek guidance on ethical dilemmas 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 this reporting tool to meet our compliance obligations while maintaining a positive reporting environment.

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?
NAVEX Global does not generate or maintain any internal connection logs with IP addresses; no information linking your PC to NAVEX Global is available. In fact, NAVEX Global is contractually committed not to pursue a reporter’s identity.

If you feel uncomfortable making a report on your US Foods PC, you have the option of using a PC outside our work environment (such as one located at a café, the library, at a friend’s house, etc.) through the NAVEX Global secure website. Many people choose this option, as NAVEX Global’s data shows that fewer than 12% of reports are opened 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 law. An Internet portal never identifies a visitor by screen name and the NAVEX Global system strips away identifying information, such as an IP address, so that anonymity is maintained. Plus, NAVEX Global is contractually committed not to pursue a reporter’s identity.
I am concerned the information I provide NAVEX Global will ultimately reveal my identity. How can you assure me that will not happen?
The NAVEX Global 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 report. For example, “from my cube next to Joe 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 law. 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 Global’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?
US Foods chooses to promote ethical behavior across the company. All unethical conduct, at any level, ultimately hurts the company and all employees, 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, it is 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 Global can help you prepare and file your report so it can be properly understood. We would rather you report a situation 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 Global system and report distribution protocols at US Foods 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 file the report?
When you file a report, either using the Internet or through NAVEX Global’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 Global 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 Global provides functionality that enables company representatives to post questions for you, even if you report anonymously. It is strongly suggested that you check the status of your report periodically 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 NAVEX Global correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity, if you so choose.
Can I still file a report if I don’t have access to the Internet?
Yes, if you don’t have access or are uncomfortable using a computer you can call the NAVEX Global toll-free hotline which is available 24 hours a day, 365 days a year – 1 888 310 7716. You can also file a NAVEX Global report from any computer that can access the Internet. You can file from home. Many public locations, including most public libraries, have Internet computers.
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, or you may email compliance@usfoods.com to report a non-working phone number. Please indicate in the report or email that the telephone number did not work.