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.

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.

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. For example, if you are in the European Union, WBA may only accept reports that relate to financial, accounting, auditing, bribery, competition and/or anti-trust law. Although we generally encourage you to identify yourself when submitting a report via the EthicsPoint system, we would rather you report anonymously (where permitted by local laws) than keep the information to yourself. 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.

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.