Frequently Asked Questions

EthicsPoint is an independent company that provides secure, confidential telephone and web-based systems for use by those who wish to report a concern regarding business conduct. LFG is one of many companies that contracts with EthicsPoint for this service in the belief that individuals will be more comfortable reporting a concern if they know they will be reporting to a professional third-party. In addition to providing service 24 hours a day, EthicsPoint offers translation services that allow telephone and web reports to be available in Spanish.

EthicsPoint's principal responsibilities are to:

• Provide confidential telephone and web-based options for employees and others to report ethics concerns and Code of Conduct concerns.
• Provide translation services for those reporters who wish to report in Spanish.
• Transmit information about the concern to the LFG Ethics team so the company can conduct an appropriate investigation.
• Allow a reporter to anonymously communicate with LFG investigators by serving as an intermediary which can relay follow-up questions and answers, as well as information about the resolution of the case when appropriate.
• It is not EthicsPoint's role to take action to address the concern, only to transmit the concern to the LFG Ethics team.

When you have a concern or observe behavior that you believe violates Company policy, the Code of Conduct or the law, you are expected to report it. You should bring any concern forward to your manager or Human Resources. If you are uncomfortable reporting your concern, if you do not know who to contact, if you believe your concern has not been satisfactorily addressed, or if you wish to remain anonymous, please proceed with the filing of a report through EthicsPoint.

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.

Please contact the HR Service Center at 866-922-6543.

To file a report using the website:

1. Select “Report A Concern” from the Ethics Hotline homepage.
2. Select an Issue Type that best describes your area of concern.
3. Fill out a report on the potential violation 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.

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 filing the new report you should mention that it is related to a report you previously filed.

You may phone the Ethics Hotline or access it through the internet. The Ethics Hotline is hosted by a third party, EthicsPoint. This confidential call center and secure internet site will receive your questions and reports. You may use the Ethics Hotline to file a report or follow up on a prior report. Whether you call or log on, you will be given instructions on how to complete your task. 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 LFG Ethics team for follow up.

It is usually easier to conduct a more complete investigation if you identify yourself and those involved because it allows the LFG investigator to directly follow-up with you and others. If you choose to identify yourself in reporting your concern, LFG 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. You will need to 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 LFG 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.

EthicsPoint does not trace phone calls or use Caller Identification. In addition, EthicsPoint does not generate or maintain internal connection logs containing Internet Protocol (IP) addresses, so no information linking your computer to EthicsPoint would be available if you choose to 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 LFG Ethics Hotline, operated by EthicsPoint, 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.

LFG 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 so that LFG can investigate.

EthicsPoint notifies the LFG Ethics team when a report is received. A determination is made whether an investigation is necessary and if sufficient information has been provided. If needed, a request for additional information from the reporter will be made. Once the report is filed, LFG reviews the details and involves the appropriate team (for example: HR, Compliance/Legal, IT, Finance, Security) to conduct the investigation. 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 LFG Ethics team to review and oversee the investigation process.