Amex Ethics Hotline – Commonly Asked Questions

What is the Amex Ethics Hotline?

The Amex Ethics Hotline is a confidential, online and phone-based tool, hosted by NAVEX, an independent third-party service provider, available any time (24/7/365) to American Express colleagues (which includes employees and contractors) and external parties, including vendors/suppliers, customers and others, to raise concerns about a potential ethics or compliance matter. Examples matters reported to the Hotline include but are not limited to concerns related to the conduct of American Express colleagues and the principles in the company’s Code of Conduct, such as financial reporting and accounting concerns; corruption, fraud or other criminal activity; misconduct in Customer Facing Interactions, including sales, marketing, advertising, servicing and collections activities; and other workplace conduct issues.

All reports made through the Amex Ethics Hotline are handled confidentially, meaning information obtained from the initial report or during the investigation is shared exclusively on a need-to-know basis. Reports submitted to the Amex Ethics Hotline may be made anonymously, if preferred. No one may be retaliated against for reporting concerns in good faith. It’s safe to speak up at American Express.

The Amex Ethics Hotline is not the only resource or channel available for raising concerns – it is an additional resource for colleagues who may alternatively choose to discuss these matters with their direct leaders, Colleague & Labor Relations, the Colleague Experience Group, the Internal Audit Group, Global Security, Compliance, the General Counsel’s Organization or as otherwise provided under local reporting procedures. If you are uncomfortable reporting your concerns directly with any of these resources (or are not a colleague), you may, as indicated above, report your concerns to the Amex Ethics Hotline.

Who oversees the Amex Ethics Hotline and reviews the concerns raised?

Reports made through the Amex Ethics Hotline (hosted by NAVEX, an independent third-party service provider) are provided to the Amex Ethics Office, a specialized team within American Express which triages and assigns reported concerns for investigation. The Amex Ethics Office sits within the General Counsel’s Organization and is a small team of American Express colleagues who have been tasked to handle matters with the utmost level of integrity, confidentiality and discretion and confirm reported concerns have been addressed. The Amex Ethics Officers do not conduct investigations. They confirm all reported concerns are promptly reviewed and addressed by the appropriate subject matter specialist team, such as Colleague & Labor Relations, Internal Audit or Global Security.

See What Happens When You Make a Report? for additional information.

Why do we need the Amex Ethics Hotline?

American Express is committed to doing right by our colleagues. Acting with integrity and protecting our company’s brand and reputation is everyone’s right and responsibility, no matter where in the company you sit. We want colleagues to feel comfortable in bringing forward issues or concerns, so we can determine whether there is conduct happening at American Express which is inconsistent with the law, regulation, Company policy or our Blue Box Values, and if so, stop it and remediate it.

By creating open lines of communication and offering confidential tools for colleagues and others to raise concerns without fear of retaliation, we promote a positive work environment and continue to foster a safe, secure and robust ethical workplace which engenders trust amongst all colleagues as well as with our customers, shareholders, suppliers and all stakeholders.

Is the Amex Ethics Hotline available to all American Express colleagues?

The Amex Ethics Hotline is available 24 hours a day, seven days a week in multiple languages by phone or online for all American Express colleagues which includes employees and contractors. It is likewise publicly available for our external stakeholders, including our customers, shareholders, suppliers and others who may have concerns about a potential ethics or compliance matter. The Hotline can be accessed globally from any phone or computer. Because the website is hosted by a third party, you do not need to use your company computer or go through The Square to access the site.

What type of situations should I report?

The Amex Ethics Hotline is designed to receive concerns regarding potential ethics and compliance matters, including those pertaining to an American Express colleague and the principles outlined in the American Express Code of Conduct, other Company policies and our Blue Box Values or applicable laws and regulations. Examples include but are not limited to concerns related to financial reporting and accounting; corruption, fraud or other criminal activity; misconduct in Customer Facing Interactions, including sales, marketing, advertising, servicing and collections activities; and other workplace conduct issues.

I am not sure if what I have observed/heard is a violation. What should I do?

When in doubt, report your concern to the Amex Ethics Hotline. We would rather you err on the side of caution than remain silent.

You need not know or confirm whether there is in fact a violation. It’s understandable that you may not know for sure, and you should not conduct your own investigation at any time; rather, if you suspect a possible violation of law, regulation or policy, report it and our subject matters specialists will investigate to determine whether there is a violation.

If I’m a colleague and I have an issue or concern, shouldn’t I report it to my leader, the Colleague Experience Group or Compliance?

When you observe behavior that raises an issue or concern related to the principles contained in the Code of Conduct, our other Company policies or applicable laws, we encourage you to report it without fear of retaliation. You can ask questions or raise concerns with your direct leader, Colleague & Labor Relations, the Colleague Experience Group, the Internal Audit Group, Global Security, Compliance, the General Counsel’s Organization or as otherwise provided under local reporting procedures.

It is up to you which resource or channel you choose based on your comfort level. We recognize that there may be circumstances when you are not comfortable reporting concerns to one of these resources, and as a result, we offer you the option of reporting your concerns to the Amex Ethics Hotline.

Why should I report a concern I may have?

Acting with integrity and protecting our company’s brand and reputation is everyone’s right and responsibility, and that means speaking up when something doesn’t feel right. Together, when we uphold our Code of Conduct, we help ensure the company operates fairly and ethically, we maintain a safe, healthy and productive work environment for everyone and we engender trust amongst all colleagues and with our customers, shareholders, suppliers and all stakeholders.

I am aware of some unethical conduct, but it doesn't affect me. Why should I report it?

Any unethical conduct, at any level, ultimately hurts the company and all colleagues. If you know of any incidents of potential misconduct or ethical violations, consider it your duty to yourself, your co- workers, our customers, shareholders, suppliers and all stakeholders to report it.

Does American Express really want me to report?

We certainly do. In fact, we encourage you to report your concerns. You know what is going on in our company – both good and bad. We cannot stop and remediate misconduct unless we know about it. 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, our colleagues and our customers. In addition, we want all of our colleagues to feel that they are empowered and enabled to speak up and speak out without fear of retaliation about any conduct potentially inconsistent with the law, regulation, our policies or values.

What is EthicsPoint?

EthicsPoint is the name of the hotline services and case management application owned and operated by NAVEX, an independent, third party supplier retained by American Express to maintain the Amex Ethics Hotline and our case management application.

How do I file a report using the Amex Ethics Hotline?

The Amex Ethics Hotline allows you to report a concern by phone or an online web portal. The Hotline is available any time (24/7/365) and in multiple languages. It can be accessed globally using any phone or computer.

Can I file a report anonymously?

Yes, you may report a concern anonymously by phone or the online web portal. If you choose to remain anonymous, which is perfectly acceptable, please be mindful that we require sufficient detail to investigate your concern. Without sufficient information, the Company may be limited in or precluded from investigating the concern or in what help, if any, can be provided.

As a result, if you choose to report your concerns anonymously, please provide as much detail as possible about the conduct in question, who is involved, who may be a witness we can speak to, and any available supporting documentation (which you can also submit). Also, be sure to check back into our system with the report key provided and your password for any questions the investigator may have for you and for updates about the status of the handling of your concern.

What if I want to be identified in my report?

It is perfectly acceptable to identify yourself when reporting concerns which also affords the investigator the ability to contact you more easily if needed outside of the hotline database. Rest assured that all information obtained when you report a concern, including your identity, as well as information obtained during the investigation is always handled confidentially – meaning information is shared only on a need-to-know basis – regardless of whether you identify yourself or choose to remain anonymous.

There is a section in the online web portal where you may identify yourself, and if you call into the Hotline, you can provide your identity and contact information when prompted to the call representative.

Does it help if I identify myself?

Yes, investigating a report is usually faster and more efficient when the investigator is able to follow-up directly with the person who reported the issue. Rest assured that all information obtained when you report a concern, including your identity, as well as information obtained during the investigation is always handled confidentially – meaning information is shared only on a need-to-know basis – regardless of whether you identify yourself or choose to remain anonymous. If you have identified yourself, they’ll make every effort to respect your confidentiality. Your identity will not be disclosed outside of those investigating your concern or issue, unless required in the course of legal proceedings, by local laws or local company mandates.

As indicated in our Code of Conduct, no one may be retaliated against for raising a concern in good faith, and we take that very seriously. It's safe to speak up at American Express.

Where do these reports go? Who can access them?

Whether reports are made online or over the phone, they are documented within NAVEX’s secure, independently hosted server to ensure confidentiality. Reports are made available to a small, specialized group within the General Counsel’s Organization called the Amex Ethics Office. The Amex Ethics Officers refer reports to designated subject matter specialists, investigators within Colleague & Labor Relations, Internal Audit or Global Security who are responsible for evaluating, investigating and resolving the issues. Each member of the Amex Ethics Office and the internal investigators who review and resolve the reports have all received specialized training in handling concerns with the utmost confidentiality and care.

See What Happens When You Make a Report? for additional information.

Can I submit supporting documentation when I file a concern?

Submitting copies of any documents, photos, emails or screenshots of communications that support your report is extremely helpful to our investigation process. If you submit a report the Hotline using the online web portal, you will have access to a link that can upload most common file types.

How can I monitor the progress of my report?

Once you have finished filing your concern either online or on the phone, you will be provided with a report key and asked to create a password. Using these unique pieces of identification, you will be able to follow up on the report, either by calling into the Hotline or visiting the website. You may need to wait a few days after your submission before you can monitor initial progress and check whether you are being asked for any additional information.

What if I lose my report key or password?

If you lose either your report key or password, you will be asked to file a new report. This enables us to maintain the highest level of confidentiality. You should mention either on the phone or in the online form that your new report relates to one submitted earlier.

Is the telephone feature of the Hotline confidential?

Yes, it is confidential. We do not record the calls or trace the source in any manner. You will be asked to provide the same information over the phone which you would provide in a report submitted through the online web portal feature of the Hotline. Call representatives are employed by NAVEX, our third-party service provider; they are not American Express colleagues. The call representative will type your responses directly into the Amex Ethics Hotline’s secure environment. The same security and confidentiality measures will be applied to telephone-based and Internet-based reports.

It is my understanding that any concern I send from a company computer generates a server log that shows every website my computer connects with. Won’t this log identify me as the reporter?

Rest assured that the Amex Ethics Hotline and the Amex Ethics Office do not generate or maintain any internal connection logs with IP addresses. Plus, NAVEX is contractually committed to never pursue a reporter’s identity. Nevertheless, if you feel uncomfortable accessing the Amex Ethics Hotline from your work computer, you can access it using any personal computer (such as your own or one located at an Internet café, the library, a friend’s house, etc.)

I am concerned that the information I provide to the Amex Ethics Hotline anonymously will ultimately reveal my identity. How can you assure me that will not happen?

All reports are maintained with the highest level of confidentiality. If you want to remain anonymous, the Amex Ethics Hotline is designed to ensure that happens. The Amex Ethics Hotline and Amex Ethics Office do not generate or maintain any internal connection logs with IP addresses, and NAVEX is contractually committed to never pursue a reporter’s identity. To further ensure your anonymity, you – as a reporting party – should be careful not to give details so specific that they could only relate to you.

What if my direct leader or other leaders are involved in my concern? Won’t they get the report and start a cover-up?

The Amex Ethics Hotline 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 file the concern?

When you file a concern through the Amex Ethics Hotline, either using the online web portal or over the phone, you receive a unique report key and are asked to select a password. With the report key and your password, you can always return at any time to the Amex Ethics Hotline (through the web portal or by phone) access the original report and add more details.

What if you have questions for me concerning my report?

The Amex Ethics Hotline website allows members of the Amex Ethics Office or internal investigators to post questions for you, even if you report anonymously. This dialogue can be helpful in ensuring your report can be properly and thoroughly reviewed and investigated. When you receive your report key and create a password when submitting your report, you will be provided with an estimated time frame for the processing of the report. We strongly suggest you check back frequently within that time frame to see if any questions have been posted. If you identified yourself in the initial report, a member of the Amex Ethics Office or an internal investigator may reach out to you directly using the contact information you provided.

Are these follow-ups on reports as secure as the initial report?

Yes, all Amex Ethics Hotline communications are held in the same strict confidence as the initial report. If you choose to report anonymously, the follow-ups are handled in the same manner, to the extent permitted by local law.