Integrity Hotline

The Integrity Hotline is a reporting tool provided by an independent company, NAVEX. Morgan Stanley uses the Integrity Hotline to promote the reporting of potential legal and ethical concerns by employees, clients, suppliers and anyone else with relevant information.
The Integrity Hotline offers secure telephone and web-based systems for reporting concerns. Translators are available covering all major languages in which Morgan Stanley does business.

Reports are entered directly on the NAVEX secure server to guard against a breach in security. NAVEX notifies Morgan Stanley when a report is received, and the appropriate team at Morgan Stanley then reviews the matter.

NAVEX will receive your report. Whether you call or use the web form, you will be given instructions on how to proceed. You also will be asked to provide as much detailed information as possible, including any relevant document(s). Your report will then be logged and routed to Morgan Stanley for review.

You are encouraged to report potential violations of law, regulation, or Morgan Stanley policy or procedure, as well as any conduct that might compromise the Firm’s reputation or the interest of its clients, or that otherwise appears improper. Examples of matters to be reported may include (but are not limited to) concerns regarding:

• legal or regulatory compliance;
• internal breaches of Firm policies or procedures;
• sales practice or market conduct violations;
• potential securities laws violations;
• bribery or other improper payments or gifts;
• fraudulent activity;
• compliance with antitrust or competition laws;
• money laundering or other suspicious activity;
• facilitation of tax evasion, either by an employee or a third party;
• inappropriate conflicts of interest;
• the integrity of the Firm’s accounting practices, internal controls, auditing matters or public filings;
• other improper or questionable conduct by other employees, supervisors, clients, counterparties, consultants, suppliers or any other third party; or
• other conduct by Morgan Stanley, or its employees, that has or may have an adverse impact on clients, markets or the Firm’s reputation.

If you are a Morgan Stanley employee, you may consult the Global Speaking Up and Reporting Concerns Policy for additional information.

Those are also options. All Morgan Stanley personnel are required to raise concerns through proper channels. If you are an employee, you may report a concern to your manager, a designated contact under a specific policy, a member of the Legal and Compliance Division or Human Resources. The Integrity Hotline is available if you prefer not to use those channels, if you believe that a concern raised through another channel has not been properly addressed or if you prefer to proceed anonymously.

Morgan Stanley is committed to a culture of ethical business practices and to complying with the letter and spirit of all applicable laws, rules and regulations. In upholding these values, we count on all of our personnel to promptly escalate potential legal and ethical issues. By speaking up when something doesn't seem right, you can help us prevent problems or stop them from getting bigger. It's part of how we do the right thing for our clients, the Firm and each other.

Reports are entered directly on the NAVEX secure server. NAVEX makes reports available to specified individuals at Morgan Stanley for review. Those individuals are trained to handle all reports discreetly and confidentially, subject to the Firm's legal and regulatory obligations.

Do not use the Integrity Hotline to report an immediate threat of physical harm or damage to property. If you require emergency assistance, please contact your local emergency services.

You may choose to raise a concern anonymously. But please remember that if you do not tell us who you are, it may be more difficult for Morgan Stanley to review or address the matters you raised or protect your position. Also, being able to directly contact a person who has raised a concern will expedite any review. The Firm therefore encourages open reporting.

The Integrity Hotline does not trace phone calls or use Caller Identification. In addition, the Integrity Hotline does not generate or maintain internal connection logs containing Internet Protocol (IP) addresses, so no information linking your computer to the Hotline will be available if you choose to make a report online. Reports from your computer would come through a secure internet portal that does not trace or show user screen names.

A report from any internet portal will remain secure and anonymous (should you choose anonymity in reporting). The Integrity Hotline never identifies a visitor by screen name and the system strips away Internet addresses so that anonymity is totally maintained. Plus, NAVEX is contractually committed not to pursue a reporter's identity.

At the end of your telephone call or web-based report, you will be provided with a report key and asked to create a password. You can use these to check the status of your report or follow up with any additional information you may have. Your checking back will also allow Morgan Stanley to ask follow-up questions, while protecting your anonymity. Keep in mind that follow up is important for anonymous reports since we have no other means to communicate with you.
If you have reported a concern by phone, please call the telephone number for your location to follow-up. Telephone numbers for your location can be found on www.morganstanley.com/integrityhotline.

The Integrity Hotline is designed to protect your anonymity. But if you wish to remain anonymous, please ensure that the substance of the report does not reveal your identity by accident. For example, "From my desk next to Jan Smith…" or "In my 33 years…".

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and a call center specialist will type your responses into the NAVEX Web site. These reports have the same security and confidentiality measures applied to them during delivery. There is a section in the report for identifying yourself, if you wish. Morgan Stanley encourages individuals making reports to identify themselves so that the information can be reviewed promptly and thoroughly. Every reasonable effort will be made, consistent with law and Firm policy, to maintain the confidentiality of any person who raises a concern in good faith. Morgan Stanley strictly prohibits retaliation against, or the victimization of, persons who raise legal or ethical concerns in good faith. Retaliation means any adverse or negative employment action taken against a person in whole or in part for reporting a concern in good faith. If you believe you have faced retaliation of any kind, please report it so that Morgan Stanley can investigate.

Speak up—even if you're not sure a violation occurred. Morgan Stanley would rather you report something that turns out to be harmless than have a potentially problematic situation go undetected.

The Integrity Hotline system and the report distribution process are designed so that any person named in a report will not be notified of it or receive access to it.

When you submit a report (either though the web portal or by phone), you will receive a report key and be asked to create a password. You can return to the Integrity Hotline later by Internet or telephone and use these to provide more detail or answer follow-up questions that Morgan Stanley may have for its review. You are encouraged to check back in, as this can help make the Firm's review more effective.

Yes, all Integrity Hotline correspondence is protected by the same safeguards.

Due to the high level of security that is maintained for these reports, if you lose your report key or password, you will need to fill out a new report. When submitting the new report you should mention that it is related to a report you previously submitted.