About the X Ethics Helpline
Reporting – General
Reporting Security & Confidentiality
Tips & Best Practices

About the X Ethics Helpline

What is the X Ethics Helpline?

The X Ethics Helpline powered by EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX to assist management and employees with addressing fraud and other misconduct in the workplace.

Why do we need an Ethics Helpline?

• We believe that our employees are our most important asset. By creating open channels of communication, we can promote a positive work environment and maximize productivity.
• Publicly traded companies are required by law to have an anonymous reporting vehicle, where permissible, to address accounting and auditing fraud directly to the audit committee.
• An effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision making at X.

Reporting – General

May I report using either the Internet or the telephone?

Yes. With the X Ethics Helpline, you have the ability to file a confidential report via either the telephone or the Internet. You may report anonymously where permitted by law.

What type of situations should I report?

The X Ethics Helpline is designed for employees and others with whom we work to report suspected misconduct, violations of law, regulation or X ethical standards.

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 some behavior that you believe violates the law, our Code of Business Conduct & Ethics, or other X policy, we expect you to report it, subject to local law. Ideally, you should raise any concerns to your direct manager or other leader. We recognize, however, that there may be circumstances where individuals would not be comfortable reporting the issue in this manner, which is why we have made the X Ethics Helpline available as a confidential reporting channel.

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

We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting the right people know if someone is not acting appropriately. By raising your questions and concerns, you give X the opportunity to look into issues and take action if necessary.

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPoint secure server to prevent any possible breach in security. EthicsPoint makes these reports available to specific individuals within X’s Compliance and Legal teams who are charged with evaluating and investigating the report, based on the type of violation and location of the incident.

Reporting Security & Confidentiality

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

The X Ethics Helpline is designed to protect your anonymity if you wish to file a report in a location that permits anonymous reporting. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the information you provide in the body of the report does not reveal your identity by accident. For example, “From my desk next to Pedro Smith…” or “In my 7 years at X…”.

Is the telephone helpline 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 X Ethics Helpline form. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the report for identifying yourself if you wish. X encourages people to identify themselves because it can greatly facilitate communications, allow X to ask questions to gather additional relevant information, and speed up any investigation.

Tips & Best Practices

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?

All unethical conduct, at any level, ultimately hurts X and its employees, including you. You only have to consider what happened in recent peer company scandals to see the disastrous effects that a seemingly harmless lapse in ethics can have on an otherwise healthy company. So if you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it.

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?

File a report. The X Ethics Helpline can help you prepare and file your report so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you weren't sure.

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 file a report, you will receive a unique user name and are asked to choose a password. You can return to the X Ethics Helpline again and access the original report to add more detail or answer questions posed by an investigator.