About EthicsPoint

Reporting – General

Reporting Security & Confidentiality

Tips & Best Practices

About the Westinghouse Ethics and Concerns Helpline (EthicsPoint solution from NAVEX)

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX to assist Westinghouse’s employees to work together with the Ethics & Compliance Department 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.
• Publicly traded companies are required by law to have an anonymous reporting vehicle to address accounting and auditing fraud directly to the audit committee.
• An effective reporting system will augment Westinghouse’s 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 though the Westinghouse Ethics and Concerns Helpline. Both methods also let you report anonymously if desired and allowed by law.

What type of situations should I report?

The EthicsPoint system is designed for employees to report any violation of our Global Ethics Code, laws, Westinghouse policies, or other concerns 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?

In most situation, it may be ideal to 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 Westinghouse has partnered with EthicsPoint. We would rather you report directly to Ethics & Compliance through a secure and confidential method than not report the information at all.

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 at Westinghouse. 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 Westinghouse - 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 at Westinghouse.

Where do these reports go? Who can access them?

Ethics and Concerns Helpline 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 Westinghouse Ethics and Compliance who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these recipients has had training in keeping these reports in the utmost confidence. Please also refer to the Ethics and Concerns Reporting and Investigations Policy (BMS-LGL-92) for further details.

Isn’t this system just an example of someone watching over me?

No. 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, and the EthicsPoint system provides you with another vehicle to do that. 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. Neither EthicsPoint nor Westinghouse can track your identity if you choose to remain anonymous.

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. Even if a Westinghouse computer does generate a server log, our policies and procedure would prohibit us from reviewing it in an attempt to identify you if reporting anonymously.

If you feel uncomfortable making a report on your work PC, you have the option of using a non-Westinghouse PC outside our work environment 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.

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

The EthicsPoint system is designed to protect your confidentiality. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the body of the report does not reveal your identity by accident. For example, “From my cube next to Jan Smith…” or “In my 33 years…”. In the event information you provide would only be known by you, which could allow someone to identify you, Ethics & Compliance will do its best to protect your confidentiality to the greatest extent possible during any investigation.

Is the telephone toll-free hot line 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 in my report?

There is a section in the report for identifying yourself, if you wish.

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?

Westinghouse 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 at other companies 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 co-workers to report it.

Please also refer to the Ethics and Concerns Reporting and Investigations Policy (BMS-LGL-92) for further details.

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'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you weren't sure. Westinghouse has a strict no retaliation policy. Even if you report information that is later determined to be harmless, there would never be retaliation against you for submitting your concern.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

No. Though in some countries, local law requires notice to the subject of a confidential report, notice would not be provided if it would jeopardize the integrity of the investigation. Therefore, Ethics & Compliance would conduct an investigation and only notify the subjects after completion. The identity of the reporter will be protected in accordance with applicable laws and regulations.

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 user name 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 Westinghouse Ethics and Compliance 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 follow-up questions from Ethics & Compliance. You and Westinghouse Ethics and Compliance personnel now have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

Are these follow-up reports as secure as the first one?

All EthicsPoint correspondence is held in the same strict confidence as the initial report, continuing under the umbrella of anonymity if requested.

Can I still file a report if I don’t have access to the Internet?

Yes. If you don’t have access to or are uncomfortable using a computer, you can call the Westinghouse Ethics and Concerns Helpline (the EthicsPoint toll-free hotline), which is available 24 hours a day, 365 days a year.