FREQUENTLY ASKED QUESTIONS

About EthicsPoint Reporting – General Reporting Security & Confidentiality Tips & Best Practices

About EthicsPoint

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX to help management and colleagues work together in addressing reports of actual or potential misconduct in the workplace, all while cultivating a positive work environment. City National Bank has retained EthicsPoint by NAVEX to host and administer the City National Bank Ethics Hotline.

Why do we need a system like EthicsPoint?

  • We believe that our colleagues are our most important asset. By creating open channels of communication, we can promote a positive work environment and maximize productivity.
  • An effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision-making.

Reporting – General

May I report using either the Internet or the telephone?

Yes. With EthicsPoint, you have the ability to file a confidential, anonymous report via either the telephone or the Internet.

What type of situations should I report?

The EthicsPoint system is designed for colleagues to raise concerns regarding compliance with applicable laws or regulations, the Code of Conduct, City National Bank policies or any other concern you may have.

Should I use the EthicsPoint system to report work-related problems or concerns about how I am treated at work?

When you have a work-related problem, question or complaint, you should first discuss it with your supervisor. The simplest, quickest, and most satisfactory solution is most often reached at this level. If the discussion with your supervisor does not answer your question or resolve the matter to your satisfaction, or you believe it is not appropriate to discuss the issue with your supervisor, or if you are not comfortable discussing the issue with your supervisor, you should bring the matter to the attention of the department manager or division head. If the problem is still not resolved, you should contact your division's human resources business partner. However, we understand that there are circumstances that may arise where discussing an issue with a manager or other resource is uncomfortable or undesirable. The EthicsPoint system provides an alternative channel for you to communicate your concerns confidentially or anonymously, if you so choose.

If I see a violation, should I just report it to my manager, security, or human resources for handling?

All colleagues have a duty to seek guidance and raise concerns about compliance with applicable laws or regulations, the Code of Conduct or City National Bank Policies. You are encouraged to bring any concerns forward to your direct manager, human resources business partner, or other member of our management team. We recognize, however, that there may be circumstances where you may not be comfortable reporting the issue in this manner. It is for such circumstances that we have partnered with EthicsPoint.

Does management really want me to report?

We certainly do. In fact, we need you to report. You know what is going on in our company and you may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the company and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.

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 only to specific individuals within the company who are charged with evaluating the report, based on the subject matter of the report and location of the incident. Each of these report recipients has had training in treating these reports with the utmost confidence.

Am I protected from retaliation if I make a report?

There will be no retaliation for speaking up and making a good faith report of actual or possible misconduct. Retaliation can include behavior or actions that punish someone for or might deter someone from speaking up. Retaliation can be an unjustified decision affecting someone’s compensation, job security, career mobility or performance rating and can also include unnecessarily monitoring someone’s work, excluding them from meetings or team events and withholding work related information. If you believe you have experienced or observed any form of retaliation for having made a good faith report, you should promptly notify your supervisor, any human resources business partner or the General Counsel for information on how to file a report of retaliation and to get assistance in resolving the situation.

Reporting Security & Confidentiality

It is my understanding that any report I send from a company computer generates a server log that shows every web-site that my PC connects with, and won’t this log identify me as a report originator?

EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available. In fact, EthicsPoint is contractually committed not to pursue a reporter’s identity.

If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside our work environment (such as one located at an Internet café, at a friend’s house, etc.) through the EthicsPoint secure website. Many people choose this option, as EthicsPoint’s data shows that fewer than 12% of reports are generated during business hours.

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is totally maintained. Plus, EthicsPoint is contractually committed not to pursue a reporter’s identity.

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

The EthicsPoint system is designed to protect your anonymity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the body of the report does not reveal your identity by accident. For example, “From my cube next to Jan Smith…” or “In my 33 years…”.

Is the telephone toll-free hot line 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 EthicsPoint Web site. 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.

Tips & Best Practices

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 are encouraged to bring any concerns forward to your direct manager, human resources business partner, or other member of our management team. We recognize, however, that there may be circumstances where you may not be comfortable reporting the issue in this manner. In those instances, file a report. EthicsPoint 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 my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The EthicsPoint system and report distribution are designed so that implicated parties are not notified or granted access to reports in which they have been named.

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 at the EthicsPoint Web site or through the EthicsPoint Call Center, you receive a unique user name and are asked to choose a password. You can return to the EthicsPoint system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a company representative and add further information that will help resolve open issues. We strongly suggest that you return to the site in the time specified to answer company questions. You and the company now have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

Are these follow-ups on reports as secure as the first one?

All EthicsPoint correspondences are treated confidentially to the fullest extent practicable, continuing under the umbrella of anonymity if reported anonymously.

Can I still file a report if I don’t have access to the Internet?

You can file an EthicsPoint report from any computer that can access the Internet. You can file from home. Many public locations, including the public library, have Internet computers. If you don’t have access to or are uncomfortable using a computer, you can call the EthicsPoint toll-free hotline, which is available 24 hours a day, 365 days a year.