About EthicsPoint

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX that enables management and employees to work together in addressing fraud, abuse, and other misconduct in the workplace while fostering a respectful work environment.

Why do we need a system like EthicsPoint?

• Our employees are our most important asset. By creating open channels of communication, we promote a respectful work environment and maximize productivity.
• Publicly traded companies in the United States are required by law to have a reporting vehicle, with the ability to report concerns anonymously if desired, to address accounting and auditing fraud directly to the audit committee. Similarly, other countries, such as countries within the European Union, the United Kingdom, and others, have laws requiring organizations provide systems for individuals to report their concerns.
• An effective reporting system augments 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. EthicsPoint enables you to file a confidential and, if desired, anonymous (where allowed by law) report via either the telephone or the Internet (Desktop or mobile).

What type of situations should I report?

The EthicsPoint system allows individuals to submit reports about potential violations of the law, our code of conduct, 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 code of conduct, you have an obligation under our code to report it. It takes courage to raise concerns, especially about an ethical issue in the workplace. It is Tennant Company’s responsibility to provide a variety of resources for raising concerns in a way that employees feel comfortable. If you have questions, or are uncomfortable about something you heard or witnessed, you have several ways to express your concerns.

You can contact:

• Your direct manager
• Your Human Resources Business Partner, or anyone in HR with whom you’re comfortable sharing your concerns
• Tennant Company’s Ethics & Corporate Compliance (E&CC) team (Ethics@tennantco.com)
• Anyone in management with whom you are comfortable sharing your concerns

We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that we have partnered with NAVEX to make the EthicsPoint system available for confidential, and if you choose, anonymous (where allowed by law) reporting. In countries and regions where anonymous reporting is not allowed, the E&CC team and any assigned investigators have protocols in place to protect the identity of the Reporter and others involved in an investigation.

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

All Tennant Company employees, temporary workers, and our Board of Directors have an obligation under our code of conduct to report their concerns about unethical or illegal conduct. We all have the right to work in a respectful 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. And corporate misconduct can threaten the very existence of an entire company.

Tennant Company prohibits retaliation against anyone who, in good faith, reports or participates in the investigation of an actual or suspected violation of the Code of Conduct. Tennant will promptly, fairly and thoroughly investigate allegations of retaliation. Individuals found to have engaged in retaliatory conduct will be subject to discipline, up to and including termination of employment or contract.

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 responsible for evaluating 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?

EthicsPoint is a positive aspect of our overall philosophy that helps us provide 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 for a respectful workplace. EthicsPoint helps to enhance that communication.

Reporting Security & Confidentiality

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

NAVEX does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available.

If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside our work environment through the EthicsPoint secure website.

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. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is 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, do not provide any details within the report from which your identity could be determined. For example, “From my cube next to Jan Smith…” or “In my 33 years…”. Some countries do not allow anonymous reporting. In countries and regions where anonymous reporting is not allowed, the E&CC team and any assigned investigators have protocols in place to protect the identity of the Reporter and others involved in an investigation.

Is the telephone toll-free hot line 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 Web site. These reports have the same security and confidentiality measures applied to them during delivery. EthicsPoint has country- specific toll-free phone numbers and website links that allow for international calls and native language conversations. Some countries do not allow anonymous reporting. In countries and regions where anonymous reporting is not allowed, the E&CC team and any assigned investigators have protocols in place to protect the identity of the Reporter and others involved in an investigation.

What if I want to be identified with my report?

There is a section in the report for identifying yourself, if you wish.

Tips & Best Practices

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

All Tennant Company employees, temporary workers, and our Board of Directors have an obligation under our code of conduct to report their concerns about unethical or illegal conduct. We all have the right to work in a respectful 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, respectful and productive environment.

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?

It takes courage to raise concerns, especially about an ethical issue in the workplace. If you have questions, or are uncomfortable about something you heard or witnessed, you have several ways to express your concerns or ask questions.

You can contact:

• Your direct manager
• Your Human Resources Business Partner, or anyone in HR with whom you’re comfortable sharing your concerns 
• Tennant Company’s Ethics & Corporate Compliance team (Ethics@tennantco.com)
• Anyone in management with whom you are comfortable sharing your concerns

Not everything submitted through the EthicsPoint system is a report of unethical or illegal conduct. Some submissions are questions seeking clarification of a policy or inquiring about how to handle an ethical dilemma. NAVEX can help you submit your concern so it can be properly understood. We'd rather you report a situation that is not a violation than let possible unethical behavior go reported.

Tennant Company prohibits retaliation against anyone who, in good faith, reports or participates in the investigation of an actual or suspected violation of the Code of Conduct. Tennant will promptly, fairly and thoroughly investigate allegations of retaliation. Individuals found to have engaged in retaliatory conduct will be subject to discipline, up to and including termination of employment or contract.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

Reports are entered directly on the EthicsPoint secure server. NAVEX makes these reports available only to specific individuals within the company who are responsible for evaluating 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. In addition, the EthicsPoint system and report distribution are designed so that implicated/named individuals 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 submit your concerns through the EthicsPoint Web site or 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 to access the report to add more detail or answer questions posed by a company representative. This allows you to communicate with the investigator assigned to the report while also maintaining your anonymity.

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

Yes. All communications and report follow-ups through EthicsPoint maintain the same level of confidentiality and anonymity as the initial report. If your initial report was submitted anonymously, the EthicsPoint site allows you to communicate with the assigned investigator while maintaining your anonymity. In countries and regions where anonymous reporting is not allowed, the E&CC team and any assigned investigators have protocols in place to protect the identity of the Reporter and others involved in an investigation.

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

Yes. If you do not have access to or are uncomfortable submitting your concerns via the Internet, you can call the EthicsPoint toll-free hotline, which is available 24 hours a day. EthicsPoint has country-specific toll-free phone numbers and website links that allow for international calls and native language conversations.

About the Investigation

Who Investigates my concerns?

Tennant’s Ethics and Corporate Compliance (E&CC) team will generally conduct investigations. Depending on the topics involved, the investigation may require involvement of Human Resources or a third party (such as a law firm, an external audit firm, forensic accountants, IT consultants or other experts).

What is Tennant Company’s stance on retaliation?

Tennant Company prohibits retaliation against anyone who, in good faith, reports or participates in the investigation of an actual or suspected violation of the Code of Conduct. Tennant will promptly, fairly and thoroughly investigate allegations of retaliation. Individuals found to have engaged in retaliatory conduct will be subject to discipline, up to and including termination of employment or contract.