What is NAVEX?
NAVEX is a comprehensive and confidential reporting tool to assist management and employees to work together to address fraud, abuse, and other misconduct in the workplace, all while cultivating a positive work environment.
Why do we need a system like NAVEX?
May I report using either the Internet or the telephone?
Yes. You may submit a report to the Compliance and Ethics Hotline, managed by NAVEX, via either the telephone or the Internet.
What type of situations should I report?
You should report suspected violations of the law, the WBA Code of Conduct and Ethics, or internal policies or procedures. If that issue is within one of the reportable topic areas applicable in your country, then you may use the NAVEX EthicsPoint system. If your concern pertains to a matter that may not be accepted by WBA through the NAVEX EthicsPoint system, you will need to contact your supervisor or local management or a representative of the Human Resources, Legal, or Compliance Departments to report the matter.
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 observe some behavior you suspect violates the law, the WBA Code of Conduct and Ethics, or internal policies or procedures, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager or other member of our management team. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances we have established a Compliance and Ethics hotline. If that issue is within one of the reportable topic areas applicable in your country, then you may use the NAVEX EthicsPoint system. If the issue is not in one of the reportable topic areas applicable in your country, please contact your supervisor or local management or a representative of the Human Resources, Legal, or Compliance Departments to report the matter.
Why should I report what I know? What’s in it for me?
We all have the right to work in a positive environment. With that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the livelihood of an entire company.
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 - both good and bad. 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 to a NAVEX secure server to maintain the confidentiality of reports. As per our agreement with NAVEX, it makes these reports available only to specific individuals within the company who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports in the utmost confidence and handling these reports in compliance with applicable law. With some exceptions, the subject of the report may receive information concerning the report (with the exception of the identity of the reporter) and request correction of personal data that is inaccurate or incomplete in accordance with applicable law. Your identity will not be disclosed to the subject of the report, however. Similarly, with some exceptions, reporters may also access information about the report and request corrections of their personal data in accordance with applicable law.
It is my understanding that any report I send from a company computer generates a server log that shows every website my PC connects with; won’t this log identify me as a report originator?
NAVEX does not generate or maintain any internal connection logs with IP addresses; no information linking your PC to NAVEX is available.
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 interviewer will type your responses directly into NAVEX’s secure environment. Hotline-based reports have the same security and confidentiality measures applied to them during delivery as Internet-based reports.
What if I want to be identified with my report?
There is a section in the report where you may identify yourself, if you wish.
I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?
You have a responsibility to report unethical business conduct and known or suspected violations of the Code or other WBA policies. An issue cannot be addressed unless it is brought to the proper person’s attention. Keep in mind that WBA does not tolerate retaliation against anyone who participates in an investigation, raises a legal or ethical concern, or reports misconduct in good faith. Good faith means that the report was made out of honest and genuine concern without ulterior motive.
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?
File a report. So long as the report is within the scope of reports that can be reported via the NAVEX system, the Compliance and Ethics hotline can help you prepare and file your report so it can be properly understood. 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 Compliance and Ethics hotline and report distribution protocols are designed so implicated parties are not notified about or granted access to reports in which they have been named. Implicated parties may be notified at some point during the course of investigating the report but your identity would not be provided as part of this notification.
What if I remember something important about the incident after I file the report?
When you file a report, either using the Internet or through NAVEX’s Contact Center, you receive a unique report key and are asked to select a password. With the report key and your password, you can return to the NAVEX system again, either by Internet or telephone, and access the original report. At that point, you can add more details.
What if you have questions for me concerning my report?
NAVEX provides functionality that enables company representatives to post questions for you, even if you report anonymously, to the extent anonymous reporting is allowed by applicable law. When you receive your report key, you will be provided with the amount of time we expect for the report to be processed. When that time has passed, we strongly suggest you check to see if any questions have been posted. Providing the opportunity for such dialogue means situations may not only be identified but can also be resolved, no matter how complex.
Are these follow-ups on reports as secure as the first one?
All correspondences through the Compliance and Ethics hotline are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity, if you so choose (and where permitted by local laws).
Can I still file a report if I don’t have access to the Internet?
You can file a Compliance and Ethics hotline report from any computer that can access the Internet. You can file from home. Many public locations, including most public libraries, have Internet computers. If you don’t have access or are uncomfortable using a computer, you can call the toll-free hotline which is available 24 hours a day, 365 days a year. Dialing instructions vary by country; verify the proper dialing instructions with a local team member.
What should I do if the telephone number is not working?
If the telephone number listed above is not functioning, please make your report online through this web site. Please indicate in the report that the telephone number did not work.