Our Commitment

At Vanguard, we strive to always do the right thing. Our policies and procedures, including our Code of Ethical Conduct, outline our expected standards of behavior.

Vanguard is committed to an environment where open, honest communications are the expectation, not the exception. We want you to feel comfortable in approaching your manager, a Compliance Officer, or Crew Relations in instances where you believe violations of Vanguard’s policies, the Code of Ethical Conduct, or any laws have occurred.

Examples of reportable concerns include, but not limited to:

• Violations of Vanguard’s Code of Ethical Conduct
• Concerns regarding financial integrity
• Concerns regarding business integrity
• Potential violations of policy, regulation, or other compliance matters
• Concerns regarding information security and privacy
• Concerns regarding workplace practices.

In addition to other internal channels, reports can be made by calling Vanguard’s toll-free Anonymous Reporting Hotline and speaking to non-Vanguard personnel who are available 24 hours a day, seven days a week, or via our web-based reporting system.

See NAVEX’s FAQs for more information.