EthicsPoint is an independent, third-party company that provides secure, confidential telephone and web-based systems for reporting concerns about business conduct. The Michaels Companies is one of many companies that contracts with EthicsPoint for this service to give Team Members a way to report concerns. In addition to providing service 24 hours a day, EthicsPoint offers translation services that allow telephone and web reports to be available in various languages.

We rely on EthicsPoint to:

• Provide confidential telephone and web-based options for Team Members and others to report ethics, Code of Business Conduct and other concerns. It is not EthicsPoint's role to take action to address the concern, only to transmit the concern to The Michaels Companies team.
• Provide translation services for those who wish to report in languages other than English
• Transmit information about the concern to The Michaels Companies team, so the company can conduct an appropriate investigation
• Allow anonymous communication with The Michaels Companies investigators by serving as an intermediary to relay follow-up questions, answers and other information about the resolution of the case.

1. Select “Report A Concern Online” from the homepage.
2. Select an issue type that best describes your area of concern.
3. Fill out a report on the concern by answering the questions provided.
4. Record the unique report key and password for your report so that you can return later to check progress or answer questions about your report.

We take the security of these reports seriously, so we cannot recall reports without the report key and password. If you lose your report key or password, please fill out a new report. When filing the new report, mention that it is related to a report you previously filed.

You may phone the Hotline or access through the internet. The Hotline is hosted by a third party, EthicsPoint, and uses its confidential call center or secure internet site to receive your questions and reports. You may use the Hotline to ask a question, to file a report or follow up on a prior report. When filing a report, you will be asked to provide as much detailed information as possible. You may also attach a document(s). Your report will be logged and routed to The Michaels Companies team for follow-up. The Michaels Companies takes all concerns seriously and will ensure timely detailed investigations of each concern.

When you have a concern or observe behavior that you believe violates Company policy, the Code of Business Conduct or the law, you are expected to report it. You should bring any concern forward to your manager, your manager’s manager, Human Resources, Loss Prevention or the legal department. Alternatively, Team Members can report concerns to Team Member Services at 855-432-MIKE (6453). If you are uncomfortable reporting your concern, if you do not know whom to contact, if you believe your concern has not been satisfactorily addressed or if you wish to remain anonymous, please file a report through NAVEX.

Concerns about an immediate threat of physical harm or damage to property should not be reported to EthicsPoint. If you require emergency assistance, please contact your local emergency services, report to your Zone Loss Prevention Manager, or contact Michaels Global Security Desk 972.409.1306.

It is usually easier to conduct a more complete investigation if you identify yourself and those involved, because it allows The Michaels Companies investigator to directly follow up with you and others. If you choose to identify yourself in reporting your concern, The Michaels Companies will make every reasonable effort to hold your name in confidence during the investigation.

You may report your concern anonymously by using the Ethics Hotline – online or by phone, which are operated by EthicsPoint. If you choose to file your report anonymously, you will be provided with a report key and asked to create a password. Retain the report key and password to the report you previously submitted. When following up on your report, you can add additional information if necessary or inquire about status. This also allows The Michaels Companies 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.

NAVEX does not trace phone calls or use Caller Identification - nor do they generate or maintain logs containing Internet Protocol (IP) addresses - so no information linking your computer to EthicsPoint is available if you make a report online. Reports from your computer would come through a secure Internet portal which does not trace or show user screen names.

At the end of your telephone call or web-based report, EthicsPoint will provide you with a report key and ask you to create a password. You will be asked to telephone The Michaels Companies Ethics Hotline, operated by NAVEX, or visit the Ethics Hotline website periodically after you make your initial report. At that time, you can learn whether any additional information is needed from you to address your concern.

The Michaels Companies strictly prohibits retaliatory acts – such as demotion, harassment or other negative acts – against any person for reporting concerns or suspected violations in good faith. Reporting in “good faith” means providing all of the information you have and that you believe to be truthful. If you believe you have faced retaliation of any kind, please report it your manager, your manager’s manager, Human Resources, Loss Prevention, or the Legal department so that The Michaels Companies can investigate.

NAVEX notifies The Michaels Companies team when a report is received. Once the report is filed, The Michaels Companies reviews the details and involves the appropriate team (i.e., HR, Legal, IT, Finance, Security) to conduct the investigation. If needed, a request for additional information from the reporter will be made. The concern is investigated promptly and confidentially.

Reports are entered directly on the EthicsPoint secure server to prevent any possible breach in security. EthicsPoint makes these reports available to The Michaels Companies Investigator to review and oversee the investigation process.

Call Team Member Services at 855-432-MIKE or email hrteam@michaels.com for support on general policy/procedure, benefits, etc. You can also visit www.MIKBenefits.com for more detailed information about benefits as well as key contacts.

SOX is a short for the Sarbanes-Oxley Act of 2002, which is a US law focused on increasing transparency in accounting practices.

You can find the Team Member Handbook in your Workday>Personal>Documents, or in MIK Hub or on The MIK intranet page.