What is Speak and Be Heard?
Speak and Be Heard is the company’s global reporting line. It is a confidential vehicle through which you can ask questions or raise concerns about our policies, including our Code of Business Conduct and Ethics. With Speak and Be Heard, you have the ability to file a confidential, anonymous report via the Internet or by telephone.
What happens when a report is made through Speak and Be Heard?
Reports received through Speak and Be Heard are entered directly on the EthicsPoint secure server, which is managed by an independent party. Only specific individuals within the company can access EthicsPoint, and each of these individuals has had training in keeping these reports in the utmost confidence.
May I contact Speak and Be Heard anonymously?
Yes. Reports made to Speak and Be Heard are not traced and are handled in a confidential manner.
The Speak and Be Heard system is designed to protect you, and the third party administering the system is contractually committed not to pursue a reporter’s identity. If you wish to report anonymously, you need to be careful not to reveal any identifying details as part of your report.
Can I be retaliated against for using Speak and Be Heard?
We will not tolerate unfair treatment or retaliation against any employee who raises concerns or reports a potential compliance issue or violation of company policy.
What type of situations should I report?
The Speak and Be Heard system is designed for employees or third parties to report any issues that may be illegal, unethical, or inconsistent with our Code and our values.
If I see a violation, shouldn’t I just report it to my manager or human resources and let them deal with it?
When you observe some behavior you believe violates our Code, we expect you to report it. You have several options to report these concerns, including speaking with your supervisor or manager, contacting Human Resources, contacting the Legal and Compliance Department, or reporting through Speak and Be Heard.
Isn’t it true that if I make my report from a company computer it generates a server log that shows every website that my PC connects with, and this log would identify me as the reporter?
No. Speak and Be Heard does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to Speak and Be Heard is available. In fact, the third party administering the Speak and Be Heard system is contractually committed not to pursue a reporter’s identity.
Is the telephone toll-free hotline confidential and anonymous too?
Yes – so long as anonymous reporting is permitted by local laws. You will be asked to provide the same information you would provide in an Internet based report; the third party interviewer will type your responses directly into the Speak and Be Heard secure environment. Telephonic-based reports have the same security and confidentiality measures applied to them as internet-based reports.
What if I want to be identified with my report? Are there advantages to identifying yourself?
There is a section in the report where you may identify yourself, if you wish. Disclosing your identity allows the company to follow up with you directly with requests for more information when necessary. Ultimately, it is your decision how you report. The important thing is to always report any concerns about known or suspected unethical behavior.
I am aware of some individuals involved with unethical conduct, but it doesn’t affect me. Why should I bother reporting it?
Our culture matters. How we respond to misconduct makes a powerful statement about the health of our culture. Please remember that our individual choices and actions, as well as what we do collectively, defines us as a company. For that reason, we must always operate with integrity. If you know of any incidents of misconduct or ethical violations, it is your responsibility to the company 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?
You have several options to report these concerns, including speaking with your supervisor or manager, contacting Human Resources, contacting the Legal and Compliance Department, or reporting through Speak and Be Heard. We would rather you report a situation that turns out to be harmless than let possibly unethical behavior go unchecked because you were unsure.
What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?
The Speak and Be Heard system and report distribution are designed so that implicated parties are not notified or granted access to reports in which they have been named. You should also know that the company does not tolerate retaliation. Our commitment to non-retaliation is set forth in our Code of Business Conduct and Ethics.
What if I remember something important about the incident after I file the report?
When you file a report through Speak and Be Heard via the website or the Speak and Be Heard call center, you receive a unique report key and are asked to choose a password. You can return to the Speak and Be Heard system via the website or call center and access your original report to: (i) update or add more detail or other information that will help address your concern(s) and/or resolve open issues; (ii) answer questions posed by a company representative; or (iii) view the status of your report. We strongly suggest that you follow-up in the time specified to answer company questions. You and the company have now entered into an “anonymous dialogue,” where ethical and compliance concerns are not only identified, but can also be resolved, no matter how complex.
What should I do if the telephone number is not working or if there are no dialing instructions for my country?
If the telephone number listed above is not functioning, please make your report online at speakandbeheard.ethicspoint.com. Please indicate in the report that the telephone number did not work or that your country location was not available. If you have any questions or concerns, you can also contact the Legal and Compliance team at compliance@hfsinclair.com.