Ethics Line

FREQUENTLY ASKED QUESTIONS

About the Kellanova Ethics Line

What is the Kellanova Ethics Line?

The Kellanova Ethics Line is a reporting hotline that provides Kellanova employees, suppliers and contractors, as well as the general public, an anonymous and confidential means of reporting suspected violations of our Global Code of Ethics, Kellanova policies, the law, or general workplace-related concerns. The Kellanova Ethics Line is operated by NAVEX, an independent third-party vendor, and is available 24 hours a day, 365 days a year.

Why do we need a reporting system?

We believe that our employees are our most important asset and our competitive advantage. By creating open channels of communication, we can promote a great environment and great experiences, which will ultimately maximize productivity. An effective reporting system helps foster a culture of integrity and ethical decision-making. Kellanova’s culture is built on a strong, ethical foundation, and operating ethically is an important component of our Kellanova Better Days™ Promise.

Is the Ethics Line anonymous?

When making a report through the Kellanova Ethics Line, you have the option to remain anonymous. The third-party vendor that manages this site, NAVEX, cannot determine your identity, nor will the Communications Specialist taking your report attempt to do so. In some cases, however, it may be helpful or necessary to provide your name and/or work location for a meaningful investigation to commence.

When to use the Kellanova Ethics Line

What type of situations can I report?

The Ethics Line is designed for employees, as well as the general public, to report any violation of Kellanova Global Code of Ethics, Kellanova policies, the laws or other concerns they may have.

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 become aware of behavior that you believe violates our Global Code of Ethics, our policies, or the law, we encourage you to report it to your manager, HR, or any other member of our management team. We recognize, however, that there may be circumstances when you are not comfortable doing so. For that reason, the Kellanova Ethics Line allows you to report your concern with the option to remain anonymous, rather than keep the information to yourself. Remember, not reporting, or turning to the other way, can have serious consequences.

Why should I report what I know?

We all have the right to work in a safe, welcoming environment that can only occur when we take seriously the responsibility of acting in an ethical manner. That responsibility includes letting the company know if someone is acting inappropriately. Unethical practices can lead to serious consequences, from negative impact to our reputation to loss of business and even legal action. Our people, our consumers, our communities and our investors expect and deserve nothing less than the highest level of ethical business practices from Kellanova and each employee of the company. By working together, we can create a healthy environment where we all can thrive.

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?

Speak Up! File a report. We would rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you were not sure. It is an honest concern if you truly believe there may be a violation of our Code, our policies, or the law, – even if you’re mistaken.

Am I protected against retaliation?

Yes. Retaliation against an Employee for reporting an issue in good faith is a violation of our Global Code of Ethics, our policies, our K Values, and potentially, the law. Any Employee who engages in retaliation, or threatens retaliation, will be subject to disciplinary action, up to and including termination.

You will be protected from retaliation when you:

  • Report what you believe is a violation of our K Values, our Global Code of Ethics, our polices or the law
  • Raise a compliance question or seek guidance about a business practice, decision, or action
  • Cooperate in an investigation of a potential violation
  • Report a violation of law to government authorities

If my leader or other members of management are involved in a violation, will they get the report?

No. Only individuals on a need-to-know basis, such as those responsible for investigating a concern, have access to reports. Implicated parties do not get notified or are granted access to reports. Eventually, during the investigation, the implicated individuals may be interviewed, but even then, or when corrective actions and recommendations are being executed, they do not receive information about or access to reports.

Submitting a report

How do I submit a report to the Kellanova Ethics Line?

You can file a confidential report either by telephone or online at kellanovaethicsline.ethicspoint.com. Just click the “Report A Concern” located on the top banner in the Ethics Line system. You may remain anonymous in either circumstance.

Where do these reports go? Who has access to my Ethics Line report?

Reports are entered directly on the NAVEX secure server. NAVEX makes these reports available only to specific individuals within Kellanova who are responsible for investigating and resolving them. Information such as the existence and details of all investigative matters contained in an Ethics Line report, regardless of whether it is anonymous, will be held in confidence and will only be shared with individuals with a reasonable and actual need to know.

If I use a Kellanova computer or tablet, will Kellanova be able to identify me?

No. NAVEX does not generate or maintain any internal connection logs with IP addresses, so no information linking the device you use to report to NAVEX is available.

If you feel uncomfortable making a report on your work device, you have the option to report from a personal device from your home or any other location with access to an internet connection. If you don’t have access to or are uncomfortable using a computer, you can call the NAVEX toll-free Ethics Line from the Report A Concern page, which is available 24 hours per day, 365 days per year. You may remain anonymous.

What happens when I contact the Ethics Line by phone?

When you contact the Ethics Line by phone, a NAVEX trained Communication Specialist will ask you questions about the issue you are reporting. It is important to provide as much factual information as possible, so the matter can be properly addressed and/or investigated.

When contacting the Ethics Line by phone, you may choose to remain anonymous.

What happens when I submit a report online?

When you contact the Ethics Line by the website, you can type your concern in your own words. We encourage you to provide as much detail as possible because that is crucial to an effective and impartial investigation.

What if I want to be identified with my report?

There is a section in the report to identify yourself, if you wish. You do not have to report anonymously. However, your report remains confidential.

Processing reports

What happens after I contact the Kellanova Ethics Line?

When you file a report through the NAVEX Web site or Call Center, you will receive a unique Report Key and will be asked to choose a password. All Ethics Line reports submitted to NAVEX are initially reviewed and evaluated by Kellanova’s Office of Ethics and Compliance and assigned to the appropriate individual(s) for investigation.

What if I want to add something about the incident after I file the report, or if Kellanova has questions for me concerning my report?

When you file a report through the NAVEX Web site or Call Center, you will receive a unique Report Key and will be asked to choose a password. You can return to the NAVEX system either online or by telephone to access your original report to add more information or answer questions posted by a Communications Specialist. If you remain anonymous, the Report Key will allow us to maintain communication with you. We encourage you to return to the site in the time specified to answer Kellanova Office of Ethics and Compliance or investigator’s questions, so your concerns can be resolved in a timely manner.

What do I do if I lose my Report Key or Password?

We take the confidentiality of Ethics Line reports seriously. To maintain your confidentiality, your Report Key and Password cannot be recovered by NAVEX or Kellanova. For this reason, it is extremely important that you keep your Report Key and Password in a safe place. If you misplace your Report Key and/or Password, you will have to contact the Kellanova’s Ethics Line at 1-888-292-7127 or kellanovaethicsline.ethicspoint.com to open a new case.

What information is available to me about the progress being made on my case?

When you use the unique Report Key to access your case, you may learn that the matter is still under investigation or that it has been closed. We cannot provide specific details on the investigation, such as: with whom we have spoken, the outcome, any disciplinary or other corrective action that has occurred. We restrict this information due to privacy concerns and to preserve the integrity of our investigations.

How long does it take to resolve an Ethics Line matter?

The time to review and investigate each report varies depending upon the nature of the allegation. Our goal is to close out all cases as quickly as possible.