Connect with Crown

FOR CROWN EMPLOYEES:

What is Connect with Crown?

Connect with Crown is a comprehensive and confidential reporting tool administered by an independent company, NAVEX/EthicsPoint. Connect with Crown assists management and employees in working together to address fraud, abuse, and other misconduct in the workplace, all while cultivating a positive work environment.

Why do we need a program like Connect with Crown?

Crown is committed to providing workplace conditions that allow employees to report concerns and issues in good faith without fear of retaliation. Crown encourages every employee to have an open and constructive relationship with his or her Supervisor and to also feel comfortable bringing concerns to the attention of his or her Department Manager, the Human Resources Department, or Compliance & Ethics. However, if an employee is not comfortable contacting a Supervisor, Manager, Human Resources, or Compliance & Ethics for any reason, Connect with Crown is available to report workplace concerns.

How does Connect with Crown work?

You can report a concern 24 hours a day, 365 days a year by either calling Connect with Crown free of charge, where available, or by reporting online. If calling, a trained specialist employed by NAVEX/EthicsPoint will take the information from you, anonymously if you desire. The information you provide via phone or online will be passed along to the appropriate Crown management representative. You will also be given a report key and will be asked to follow-up with Connect with Crown by phone or online at a later date. This will allow Crown to prepare follow-up questions about your workplace concern if further clarity is needed.

I am in the European Union or my report relates to activities in the European Union, are there special restrictions that apply?

Yes. If you are reporting from the European Union, or the concern you are reporting relates to the European Union, there are special restrictions that apply to the types of reports that you can make.

May I report using either the Internet or the telephone?

If a phone number is provided for your country, you can file a confidential and anonymous report via either the telephone or the Internet.
If a phone number is not listed for your country, you can only file a report via the Internet.

What type of situations should I report?

If I see a violation, should I just report it to my manager, security, or human resources and let them deal with it?

Ideally, you should bring any concerns forward to your direct Manager, Supervisor, the Human Resources Department, 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. When you observe some behavior that you believe violates law or our Code of Conduct, we expect you to report it. Connect with Crown allows you to report through a third-party, NAVEX/EthicsPoint, on a confidential and anonymous basis.

Does management really want me to report?

We certainly do. In fact, we need you to report. Crown’s outstanding reputation in the material handling industry and the community has taken years to develop. Crown’s reputation of integrity has been developed by its employees doing the right thing on a repeated basis. Unfortunately, that reputation can be tarnished very quickly by inappropriate behaviors or the actions of just one or two individuals. Your reporting can minimize the potential negative impact on Crown and our employees. Also, offering positive input may help identify issues that can improve corporate culture and performance.

Should I be nervous that filing a report might have negative consequences for me?

No. Crown is committed to providing workplace conditions that allow employees to report concerns and raise issues without fear of retaliation. Retaliation against a person who reports in good faith a violation of the Code or applicable law, raises compliance questions or issues, or cooperates in an investigation of a potential violation, will not be tolerated. If you have any concerns that you have been retaliated against, immediately contact your local Human Resource Department, Compliance & Ethics, or the Legal Department.

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

An anonymous 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 NAVEX/EthicsPoint system strips away Internet addresses so that anonymity is totally maintained. Plus, NAVEX/EthicsPoint is contractually committed not to pursue a reporter’s identity if that person has reported on an anonymous basis.

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

Connect with Crown is designed to protect your anonymity. However, if you wish to remain anonymous, you, as a reporting party, should not provide your name or contact information and you need to ensure that the body of the report does not reveal your identity by accident. Nevertheless, it is possible that in the course of an investigation of the issues you raise, Crown personnel may contact you if, even though they are unaware you made the report, it is believed that you may have information relevant to the situation. In any case, retaliation against someone who has reported, in good faith, or participates in an investigation of misconduct is strictly prohibited.

Is the telephone toll-free hotline confidential and anonymous too?

Yes. If you report by telephone, 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 NAVEX/EthicsPoint portal. 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.

Where do these reports go? Who can access them?

Reports are entered directly on the NAVEX/EthicsPoint secure server to prevent any possible breach in security. NAVEX/EthicsPoint makes these reports available only to specific individuals within Crown or its subsidiaries or affiliates who are charged with evaluating the report, deciding whether to proceed with an investigation, and ensuring a proper investigation is performed in a professional and confidential manner. Some of such individuals may be located outside of the United States.

I am not sure if what I have observed or heard is a violation of law, our Code of Conduct, company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

File a Report. If you are uncertain, we would prefer that you report the situation rather than allowing potentially unethical or illegal behavior to continue. Crown has a strict non-retaliation policy as long as you report in good faith even if it turns out that you are mistaken.

What if I remember something important about the incident after I file the report? Or what if Crown has further questions for me concerning my report?

When you file a reportthrough the Connect with Crown website or by calling Connect with Crown, you receive a unique report key and are asked to choose a password. You can reconnect with Connect with Crown either by Internet or telephone and access the original report to add more detail or answer questions posed by a Crown representative and add further information that will help resolve open issues. We encourage you to return to the website or place a follow-up call in the time specified to answer company questions. Doing so will assist in a timely review of your report.

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

All correspondence through Connect with Crown is held in the same strict confidence as your initial report.

FOR THIRD PARTIES:

What is Connect with Crown?

Connect with Crown is a comprehensive and confidential reporting tool administered by an independent company, NAVEX/EthicsPoint. Connect with Crown assists management, Crown employees and others in working together to address fraud, abuse, and other misconduct relating to Crown.

How does Connect with Crown work?

You can report a concern 24 hours a day, 365 days a year by either calling Connect with Crown free of charge, where available, or by reporting online. If calling, a trained specialist employed by NAVEX/EthicsPoint will take the information from you, anonymously if you desire. The information you provide via phone or online will be passed along to the appropriate Crown management representative. You will also be given a report key and will be asked to follow-up with Connect with Crown by phone on online at a later date. This will allow Crown to prepare follow-up questions about your concern if further clarity is needed.

I am in the European Union or my report relates to activities in the European Union, are there special restrictions that apply?

Yes. If you are reporting from the European Union, or the concern you are reporting relates to the European Union, there are special restrictions that apply to the types of reports that you can make.

May I report using either the Internet or the telephone?

If a phone number is provided for your country, you can file a confidential and anonymous report via either the telephone or the Internet.
If a phone number is not listed for your country, you can only file a report via the Internet.

What type of situations should I report?

As a third party, you should only report concerns that relate to your business with Crown. Any other matters may be referred by Crown to Crown’s primary contact at your company. Crown may not act upon information that you report through Connect with Crown if it relates to matters other than those that directly impact Crown.
Please note that third parties located in the European Union and certain countries may only report misconduct relating to accounting; internal accounting controls; auditing matters; bribery; banking; financial crimes; discrimination or harassment; environmental protection, health or safety; customs, trade or competition laws; data privacy; and quality, regulatory, or manufacturing standards through Connect with Crown. If your concern relates to other issues, you should contact the appropriate personnel in your company.

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

An anonymous 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 NAVEX/EthicsPoint system strips away Internet addresses so that anonymity is totally maintained. Plus, NAVEX/EthicsPoint is contractually committed not to pursue a reporter’s identity if that person has reported on an anonymous basis.

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

Connect with Crown is designed to protect your anonymity. However, if you wish to remain anonymous, you, as a reporting party, should not provide your name or contact information and you need to ensure that the body of the report does not reveal your identity by accident. Nevertheless, it is possible that in the course of an investigation of the issues you raise, Crown personnel may contact you if, even though they are unaware you made the report, it is believed that you may have information relevant to the situation. In any case, retaliation against someone who has reported, in good faith, or participates in an investigation of misconduct is strictly prohibited.

Is the telephone toll-free hotline confidential and anonymous too?

Yes. If you report by telephone, 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 NAVEX/EthicsPoint portal. 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.

Where do these reports go? Who can access them?

Reports are entered directly on the NAVEX/EthicsPoint secure server to prevent any possible breach in security. NAVEX/EthicsPoint makes these reports available only to specific individuals within Crown or its subsidiaries or affiliates who are charged with evaluating the report, deciding whether to proceed with an investigation, and ensuring a proper investigation is performed in a professional and confidential manner. Some of such individuals may be located outside of the United States.

What if I remember something important about the incident after I file the report? Or what if Crown has further questions for me concerning my report?

When you file a report through the Connect with Crown website or by calling Connect with Crown, you receive a unique report key and are asked to choose a password. You can reconnect with Connect with Crown either by Internet or telephone and access the original report to add more detail or answer questions posed by a Crown representative and add further information that will help resolve open issues. We encourage you to return to the website or place a follow-up call in the time specified to answer company questions. Doing so will assist in a timely review of your report.

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

All correspondence through Connect with Crown is held in the same strict confidence as your initial report.