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Commonly Asked Questions


What is the Amex Ethics Hotline?

What is the Amex Ethics Hotline?

The Amex Ethics Hotline is a confidential, online and phone-based tool, hosted by NAVEX Global, Inc., an independent third-party service provider, and available any time to American Express colleagues, contractors, vendors/suppliers, and others to raise concerns about a potential ethical or compliance matter. Examples of such matters include, but are not limited to, concerns or issues related to American Express colleagues or leaders and the principles in the company’s Code of Conduct, such as financial reporting and accounting; corruption, fraud or other criminal activity; and workplace conduct.

The Amex Ethics Hotline is not the only channel for raising concerns – it is an additional resource for colleagues and contractors, all of whom may also choose to discuss these matters with their direct leaders, Employee Relations, Human Resources, Compliance, the General Counsel’s Organization, or as otherwise provided under local reporting procedures. If you are uncomfortable reporting your concerns with any of these channels (or are not an colleagues or contractor), you may report to the Amex Ethics Hotline via telephone or website.

All reports made through the Amex Ethics Hotline are confidential, and can be made anonymously in most markets. No one will be disciplined for raising good-faith concerns.

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

Reports made through the Amex Ethics Hotline (hosted by an independent third-party service provider) are sent to a specialized team within American Express called the Amex Ethics Office, which was established in 2017. This 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. The Amex Ethics Officers do not conduct investigations, but rather ensure all reports are reviewed promptly and confidentially by the appropriate group, such as Employee Relations, Internal Audit, or Global Security so that each matter can be properly addressed.

The document, What Happens When You Make a Report? has additional details: Click here

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 our colleagues to feel comfortable in bringing forward issues or concerns.

By creating open lines of communication, and offering confidential tools for colleagues, contractors and others to raise concerns without fear of retaliation, we can promote a positive work environment and continue to foster a safe, secure, and ethical workplace.

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 to all American Express colleagues and contractors (the launch date may vary by market and is subject to local consultation). The Hotline can be accessed 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 for concerns or issues regarding ethical and compliance matters, including those pertaining to an American Express colleague or leader and the principles outlined in the American Express Code of Conduct, our other corporate policies, or applicable laws.

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

You are encouraged to report your concern to the Amex Ethics Hotline. We would rather you err on the side of caution than remain silent.

If I’m a colleague or contractor and I have an issue or concern, shouldn’t I report it to my leader, Human Resources, or Compliance?

When you observe behavior that raises an issue or concern related to the principles contained in the Code of Conduct, our other corporate 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, Employee Relations, Human Resources, Compliance, the General Counsel’s Organization, or as otherwise provided under local reporting procedures. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. This is why we have established 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 and that we maintain a safe, healthy, and productive work environment.

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 and your co-workers 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. 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. In addition, we want all of our colleagues to feel that they are empowered and enabled to speak up and speak out if there are any issues or concerns.

REPORTING – GENERAL

What is EthicsPoint?

EthicsPoint is the name of the hotline services and case management application owned and operated by NAVEX Global, Inc., which has been 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 or issue by phone or online. The Hotline is available any time and in multiple languages. It can be accessed using any phone or computer. Easy to follow steps are available at http://amex.ethicspoint.com.

Can I file a report anonymously?

It depends on the market. Based on applicable local laws and company mandates, you may be able to report a concern or issue anonymously by phone and online.

How do I know if my local market laws allow for anonymous reporting?

If you are using the Amex Ethics Hotline website and reporting from a market that allows for anonymous reporting, the system will allow you to select that option. If you are reporting from a market where local law does not allow anonymous reporting, the system will not offer that option.

The same applies when you call into the Hotline. The call representative will advise whether or not you can report anonymously based on your market.

What if I want to be identified in my report?

There is a section in the online report where you may identify yourself, if you wish. If you call into the Hotline, you can give the call representative your contact information.

Does it help if I identify myself?

Investigating a report is usually faster and more efficient when the Amex investigators are able to follow up directly with the person who reported the issue. 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. Our Code of Conduct policy clearly states that no one can be punished for raising a concern in good faith, and we take that very seriously.

Where do these reports go? Who can access them?

Whether reports are made online or over the phone, they are recorded on NAVEX Global’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 will refer the reports to appropriate investigators within Employee 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. The document, What Happens When You Make a Report? has additional details: Click here

Can I submit supporting documentation when I file a concern?

Submitting copies of any documents that will support your report is extremely helpful to our investigation process. If you submit a report online, 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 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.

REPORTING SECURITY & CONFIDENTIALITY

Is the telephone Hotline confidential?

Yes. You will be asked to provide the same information you would provide in an Internet-based report. Call representatives are employed by 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?

The Amex Ethics Hotline and the Amex Ethics Office do not generate or maintain any internal connection logs with IP addresses. 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.). Plus, NAVEX Global is contractually committed not to pursue a reporter’s identity.

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

All reports will be maintained with the highest level of confidentiality. If you want to remain anonymous, the Amex Ethics Hotline is designed to ensure that happens (where allowed by local laws). 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 via the Amex Ethics Hotline, either using the Internet 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 return to the Amex Ethics Hotline again (either by Internet or telephone), 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, 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 correspondences 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.