Frequently Asked Questions

Why has Vanguard contracted with NAVEX for reporting concerns?

NAVEX is an independent company that provides secure, confidential telephone and web-based systems for use by those who wish to report a concern regarding business conduct. Vanguard is one of many companies that contracts with NAVEX for this service as it is a best practice to provide the opportunity to speak with a professional third-party reporting service.

What is the role of NAVEX?

NAVEX's principal responsibilities are to:

  • Provide confidential telephone and web-based options for crew members and others to report concerns.
  • Transmit information about the concern to the appropriate Vanguard contact so the company can conduct an appropriate investigation.
  • Allow a reporter to anonymously communicate with Vanguard investigators by serving as an intermediary which can relay follow up questions and answers, as well as information about the resolution of the case.
  • It is not NAVEX's role to take action to address the concern, only to transmit the report to the appropriate Vanguard contact.

How does Vanguard investigate reports?

NAVEX notifies Vanguard when a report is received. A determination will be made whether an investigation is necessary and if sufficient information has been provided. If needed, a request for additional information from the reporter will be made. Once the report is filed, Vanguard reviews the details and involves the appropriate contact (e.g., Compliance, Human Resources, Legal, Security) to conduct the investigation. The report is investigated promptly and thoroughly.

Where do these reports go?

Reports are entered directly on the NAVEX secure server to prevent any possible breach in security. NAVEX makes these reports available to Vanguard and involves the appropriate contact to review and oversee the investigation process.

What should I do if I lose my report key or forget the password I created?

Because of the high level of security that is maintained for these reports, if you lose your report key or password, you will need to file a new report. Within the new report, please mention that your new submission is related to the report you filed previously.

What happens when I file a report using the Anonymous Reporting Hotline?

The Anonymous Reporting Hotline is hosted by a third party, NAVEX, and uses its confidential call center or secure website to receive your reports. You may use the Anonymous Reporting Hotline to file a report or follow up on a prior report. Whether you call in or log on, you will be given instructions on how to complete your task. When filing a report, you will be asked to provide as much detailed information as possible. You may also attach a document(s). Your report will be logged and routed to the appropriate Vanguard contact for follow up.

What types of situations should be reported?

You should report any situations that are in violation of the Code of Ethical Conduct, Vanguard policies, laws, or regulations related to our business, workplace practices, compliance matters, or ethical matters. Examples of scenarios of you should report to the Anonymous Reporting Hotline include but are not limited to:

  • Bribery
  • Theft
  • Concerns about business integrity
  • Violations of policy, procedure, or law
  • Conflicts of interest
  • Money laundering or other suspicious activity
  • Improper or questionable workplace practices by other Vanguard crew, clients, suppliers, or any other third- party

Why should I report what I know?

At Vanguard, we strive to always do the right thing. Doing the right thing also means that we should not, and will not, condone any conduct—by anyone—that is contrary to these principles. We are committed to ensure an ethical culture for the interest of our clients and crew. Our policies and procedures set our expected standards of ethical conduct. Vanguard is committed to a safe and open environment in which all Vanguard employees feel comfortable speaking up. To read more about our ethical standards click here for more information.

Should I report my concern to my manager, Human Resources, or through the Anonymous Reporting Hotline or Website?

When you have a concern or observe behavior that you believe violates company policy, laws, or regulations relating to Vanguard business, you are expected to report it. You should bring any concern forward to your manager, the next level of management, Crew Relations, or a Compliance Officer. You may also report via the Hotline or secure website - anonymously if you prefer.

What if this is an emergency?

Reports about an immediate threat of physical harm or damage to property should not be reported to NAVEX. If you require emergency assistance, please contact 911 or your local emergency services.

Can I report my concern anonymously?

Yes, you may report your concern anonymously – online or by phone, both are operated by NAVEX. If you choose to file your report anonymously, you will be provided with a report key and asked to create a password. You will need to retain the report key and password to the report you previously submitted. When following up on your report, you can add additional information if necessary or inquire about status. This also allows Vanguard to ask follow-up questions, while protecting your anonymity. Keep in mind that follow-up is important for anonymous reports since we have no other means to communicate with you.

How does NAVEX maintain anonymity?

NAVEX does not trace phone calls or use Caller Identification. In addition, NAVEX does not generate or maintain internal connection logs containing Internet Protocol (IP) addresses, so no information linking your computer to NAVEX would be available if you choose to make a report online. Reports from your computer would come through a secure Internet portal which does not trace or show user screen names.

Should I identify myself?

It is usually easier to conduct a more complete investigation if you identify yourself and those involved because it allows the Vanguard investigator to directly follow-up with you and others. If you choose to identify yourself in reporting your concern, Vanguard will make every reasonable effort to hold your name in confidence during the investigation.

What if I face retaliation?

Vanguard strictly prohibits retaliatory acts – such as demotion, harassment or other negative acts – against any person for reporting concerns or suspected violations in good faith. Reporting in “good faith” means providing all the information you have and that you believe to be truthful. If you believe you have faced retaliation of any kind, please report it so that Vanguard can investigate.

Will I receive a notification when there is an update to my report?

You will not receive a notification that an update is available unless you provided a valid email address upon submitting your initial report and chose not to be anonymous. To obtain updates regarding your report, you are encouraged to check back regularly utilizing your report key and password.