Frequently Asked Questions
Reporting Security & Confidentiality
About EthicsPoint
What is the Ethics Line?
The Ethics Line is a global helpline. It is a confidential resource through which you can ask questions and raise concerns about ethics, compliance or Momentive’s Code of Conduct. You can either report your concern online through this website, or over the phone using the Ethics Line number for your country.
What is EthicsPoint?
EthicsPoint is a comprehensive and confidential reporting tool that assists companies in addressing fraud, abuse, and other misconduct in the workplace, all while cultivating a positive work environment.
Why do we need a system like EthicsPoint?
- We believe that our employees are our most important asset. By creating open channels of communication, we can promote a positive work environment and maximize productivity.
- We believe that an effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision-making.
Reporting – General
May I report using either the Internet or the telephone?
Yes. With EthicsPoint, you have the ability to file a confidential, report via either the telephone or the Internet.
What type of situations should I report?
The EthicsPoint system is designed for employees to report any violation of our stated Code of Conduct, or other concern you may have.
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 that you believe violates our code of conduct, 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 that we have partnered with EthicsPoint.
Why should I report what I know? What’s in it for me?
We all have the right to work in a positive environment and 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 on the EthicsPoint secure server to prevent any possible breach in security. EthicsPoint 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.
Isn’t this system just an example of someone watching over me?
The EthicsPoint system concentrates on being a positive aspect of our overall philosophy, and allows us to assure a safe, secure, and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern. Effective communication is critical in today’s workplace and this is a great tool to enhance that communication.
We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment.
What if I am intimidated or retaliated against for making a report?
Momentive strictly prohibits and has zero-tolerance for any intimidation or retaliation against any person who reports, in good faith, a compliance concern. If you believe you have faced intimidation for reporting or attempting to report your concerns or actual or attempted retaliation, please report it to the Ethics Line so that Momentive can initiate a review.
Reporting Security & Confidentiality
It is my understanding that any report I send from a company computer generates a server log that shows every web-site that my PC connects with, and won’t this log identify me as a report originator?
EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available. In fact, EthicsPoint is contractually committed not to pursue a reporter’s identity.
If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside our work environment (such as one located at an Internet café, at a friend’s house, etc.) through the EthicsPoint secure website. Many people choose this option, as EthicsPoint’s data shows that fewer than 12% of reports are generated during business hours.
Can I file a report from home and still remain anonymous?
A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous where permitted by local law. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is totally maintained where permitted by law. Plus, EthicsPoint is contractually committed not to pursue a reporter’s identity.
Is the telephone toll-free hotline confidential and anonymous too?
Yes. 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 EthicsPoint Web site. 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 or where required by law.
Does it help if I identify myself?
Investigating a report is usually faster and more efficient when the Momentive Team is able to follow up on the issue directly with the person reporting the matter. If you have identified yourself, reasonable efforts will be made to respect your confidentiality. Your identity will not be disclosed unless necessary for carrying out a proper investigation, required in the course of legal proceedings, or as required by local laws or local company mandates. Momentive will not tolerate any form of retaliation for reporting a concern in good-faith.
Tips & Best Practices
I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?
Our company chooses to promote ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. You only have to consider what happened in recent corporate scandals to see the disastrous effects that a seemingly harmless lapse in ethics can have on an otherwise healthy company. So if you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it. There are also situations where, if you knew about the behavior, but failed to report or otherwise take action, you may also be held responsible.
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. EthicsPoint can help you prepare and file your report so it can be properly understood. We prefer that you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you weren't sure.
What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?
The EthicsPoint system and report distribution are designed so that implicated parties are not notified or granted access to reports in which they have been named.
What if I remember something important about the incident after I file the report? Or what if the company has further questions for me concerning my report?
When you file a report at the EthicsPoint Web site or through the EthicsPoint Call Center, you receive a unique report key and are asked to choose a password. You can return to the EthicsPoint system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a company representative and add further information that will help resolve open issues. We strongly suggest that you return to the site in the time specified to answer company questions. You and the company now have entered into a dialogue, where situations are not only identified, but can also be resolved, no matter how complex.
How can I monitor the progress of my concern if I choose to remain anonymous?
Once you have finished reporting your concern, you will be provided with a report key and asked to create a password. With these two pieces of identification, you will be able to follow up on a report, either by visiting the Ethics Line online or by telephone. You may need to wait a few days after your submission before you can monitor progress and check whether you are being asked for any additional information. To allow for protection of the matter and any parties involved, details of the case cannot be provided.
What if I lose my report key or password?
In order to maintain the highest level of confidentiality, you will be asked to file a new concern if you lose either your report key or your password. You should mention that your new report relates to one filed earlier and include the report number, if possible.
Can I still file a report if I don’t have access to the Internet?
You can file an EthicsPoint report from any computer that can access the Internet. You can file from home. Many public locations, including the public library, have Internet computers. If you don’t have access to or are uncomfortable using a computer, you can call the EthicsPoint toll-free hotline, which is available 24 hours a day, 365 days a year.