The Western Union Business Integrity Helpline (“Business Integrity Helpline”) is a secure way for employees1 to report issues or concerns or ask questions about the Code of Conduct. The Business Integrity Helpline is administered by NAVEX, an external, independent, third-party vendor. The Business Integrity Helpline supplements, and is not a replacement for, Western Union’s regular information and reporting channels. You may decide to discuss issues with your supervisor or manager, a more senior manager, Human Resources, Employee Relations, the Business Integrity Office, or use any of the resources listed in the Code of Conduct. In general, employees can make anonymous reports to the Business Integrity Helpline; but anonymous reports may be prohibited in certain countries.
The following questions and answers are intended to help you understand how the Business Integrity Helpline works and how you can use it most effectively.
You may make a report or ask a question either by visiting the Business Integrity Helpline internet site at wuethicshelpline.com or by calling one of the toll-free numbers for your country listed at wuethicshelpline.com. Both are available 24 hours a day, seven days a week, 365 days a year. Calls are answered in most languages.
All phone calls and reports to the Business Integrity Helpline are initially received by employees of NAVEX. NAVEX, is an independent third-party vendor that provides helpline services for thousands of companies in a variety of industries worldwide. The website is hosted on NAVEX’s secure servers and is not part of the Western Union web site or Intranet. NAVEX is certified under the EU-U.S. and Swiss-U.S. Privacy Shield Programs through the United States Department of Commerce as having security measures in place to address EU privacy initiatives, such as the GDPR, and other global privacy directives.
No. The NAVEX representative is not a Western Union employee and does not have in-depth knowledge about the Company or its policies. Accordingly, they are not able to give advice about business integrity concerns or questions. Instead, they will deliver a report of your Business Integrity Helpline report electronically to the Western Union Business Integrity Office, which will then respond to your concern or question.
Reports made to the Business Integrity Helpline by telephone are routed to representatives who speak the reporter's native language. NAVEX handles calls in most languages. Reports to the NAVEX website may be made in any language. The Business Integrity Helpline website may be viewed in English, French, German, Italian, Lithuanian, and Spanish.
The Business Integrity Helpline is designed to receive reports and answer questions about the Code of Conduct. In many European Union countries, the matters that may be reported are related to accounting and auditing, corruption or bribery, fraud, and insider trading. Where permitted by applicable law, additional matters may be reported through the Business Integrity Helpline.* For example, you could use the Business Integrity Helpline to report that someone may be violating the Code of Conduct or Company policy or breaking the law. You could also use the Business Integrity Helpline to ask whether an action you are considering is consistent with the Code of Conduct or Company policies.
* In France, reports may be received about any crime; serious and obvious breach of law, regulation, or international commitment ratified or approved by France; or a serious threat or harm to the public interest.
Not only do Business Integrity Helpline reports enable the Company to guard against ethical problems that could damage our reputation and business, the reports also help individual employees resolve problems in their unit or location and make the Company a better place to work for all of us.
The Business Integrity Helpline is an important tool for preventing and detecting business integrity issues. However, employees should be sure they use it appropriately. Making a deliberately false or misleading report is a misuse of the Business Integrity Helpline, and employees who do so may be subject to discipline, up to and including termination of employment. Employees who make a report in good faith (meaning they believe the report to be true and accurate) are protected from retaliation or disciplinary action for filing the report, even if it turns out their belief was mistaken. Employees who knowingly file an inaccurate report are not entitled to that protection.
Yes. Reports can be made anonymously from most locations. There may be times where identifying yourself will be useful in helping Western Union with its review; however, you may choose to report anonymously subject to applicable law.
The NAVEX website for the Business Integrity Helpline page is hosted on NAVEX’s secure servers and is not part of the Western Union web site or Intranet. NAVEX does not use caller ID or record reports made by telephone. Although the Western Union Business Integrity Office may send a response through NAVEX asking you if you are willing to discuss your report, neither Western Union nor NAVEX will attempt to identify you. Please keep in mind that if you wish to remain anonymous (where permitted by applicable law), it is important that you do not discuss your report with others.
Whether you chose to provide your name or not, your report will be treated confidentially, which means that, when appropriate, the Western Union Business Integrity Office may share information about your report with others, but only to the extent necessary to conduct an effective investigation, resolve the matter, or report significant issues to senior management or the Company's Board of Directors. In addition, the Company could provide information about your report in the course of a legal or regulatory proceeding or as required by law.
You can protect your confidentiality if you do not tell others about your report or discuss with others any communication you may have with the Western Union Business Integrity Office in connection with your report. Finally, as described below, the Company has a non-retaliation policy and does not tolerate any retaliation against employees who raise or report issues in good faith.
Before final submission of your report, you will receive an access code for your report called a “Report Key” and will have the opportunity to create a password so that you can access your report in the future to update information, ask questions, or respond to questions or comments that Western Union may post to you. Because Western Union often sends follow-up requests for additional information to assist it in review and investigation of concerns, it is important that you check back on the status of your report and provide any needed additional information so the issues you have reported can be investigated. Please do not share your Report Key or password with others.
A report of your online report or your call is delivered electronically by NAVEX to Western Union. In most cases, the Western Union Business Integrity Office acknowledges receipt of your report within 48 hours either via the NAVEX system or by Company phone or e-mail if you have provided your name and/or contact information.
Upon receipt, the Western Union Business Integrity Office reviews the report and determines whether an investigation is appropriate. If additional information is needed, Western Union will correspond with you using the messaging feature within the NAVEX system or by Company phone or e-mail if you have provided your name and/or contact information. Western Union may respond to requests for advice, contact you for more information, assign the issue to an investigator, or take other actions.
The Western Union Business Integrity Office takes every report seriously, and all reports are reviewed. What action is taken depends on the nature of the report and the amount of information provided. Where a reporter has simply asked for information or has questions about a Code of Conduct or business integrity question (e.g., whether it is appropriate to accept a gift), an investigation generally will not be necessary. If the report does not allege a legal or ethical violation or a violation of the Company's Code of Conduct or policies, an investigation will generally not be conducted. In most cases, however, some form of investigation will be undertaken. This may involve asking the reporter for additional information, obtaining information from others, reviewing Company records, and interviewing possible witnesses. Keep in mind, however, that the ability to conduct a meaningful investigation may depend on the amount of information you are able to provide.
Most investigations are conducted or overseen by members of the Western Union Business Integrity Office. Depending on the nature of the matter being investigated, they may be assisted by personnel in other areas of the Company, such as Employee Relations, Human Resources, Legal, Finance, Audit, Security, Compliance, or Procurement. Western Union may also assign the investigation to someone with subject matter expertise in the matter being investigated. In such cases, the Western Union Business Integrity Office will oversee the investigation to ensure that it is properly conducted and will receive a report back on its findings. In more significant cases, the investigation may be conducted by outside counsel or outside experts. The Western Union Business Integrity Office monitors or tracks the progress of all investigations of matters reported through the Business Integrity Helpline.
As an employee, your responsibility during an investigation is to cooperate fully and provide truthful and complete information. You may be asked to maintain the confidentiality of your report to protect the integrity of an investigation.
You must not interfere with an investigation, attempt to influence another person’s participation, or suggest potential consequences for providing information. Employees, including managers, who fail to cooperate in or interfere with an investigation or who engage in retaliation may be subject to disciplinary action up to and including termination of employment.
Western Union will normally advise you of the general outcome of the investigation. However, to protect the privacy of individuals involved, information about specific disciplinary or employee corrective recommendations or action taken is generally not shared.
Western Union prohibits retaliation against employees who raise issues or concerns or participate in investigations in good faith. If you believe you have suffered retaliation or adverse treatment for making an Business Integrity Helpline report or participating in an investigation, please contact the Western Union Business Integrity Office, your manager, a more senior manager, Human Resources, Employee Relations, the Business Integrity Helpline or any other party listed in the Resources section in the Western Union Code of Conduct so that appropriate action can be taken. Employees, including managers, who engage in retaliation may be subject to disciplinary action up to and including termination of employment.
1 As well as external and occasional associates in France.