Reporting Security & Confidentiality
About Speak Up
What is Speak Up?
Speak Up is a comprehensive and confidential reporting tool that exists to help Huntsman, its associates, stakeholders, and other interested parties address unethical behavior. It consists of a website and toll-free telephone line through which potential violations of our Business Conduct Guidelines and other unethical behavior can be reported. Speak Up access is available 24 hours a day, 7 days a week, and offers a translation service that can handle the language requirements of the global environment in which Huntsman operates.
Who Operates Speak Up?
To maximize the confidentiality of communications, Speak Up is run by NAVEX, on their EthicsPoint platform. NAVEX is a third-party company, that specializes in ethics and compliance programs. NAVEX’s primary responsibilities are to provide a service through which people can report concerns or potential ethics violations to Huntsman, protect the identity of reporters who wish to remain anonymous, and provide translation services for those who wish to report an incident in their local language. Once a concern has been submitted to NAVEX, it will be forwarded to Huntsman Ethics & Compliance for further investigation and resolution.
Why do we need Speak Up?
There are many channels through which concerns can be reported directly to Huntsman including your line manager, Human Resources, Legal and the local Facility Compliance Officer (FCO). However, we recognize that under certain circumstances individuals may be more comfortable utilizing a third-party service to alert Huntsman to potential violations and misconduct. As such, we offer the Speak Up tool to encourage those stakeholders who may otherwise be reluctant to bring forth good faith reports of unethical behavior. We would rather you report anonymously than keep the information to yourself. As a 24-hour service Speak Up is convenient and available whenever an individual is ready to come forward with a concern. We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment.
Reporting – General
What ways can I report a concern through Speak Up?
You have the ability to file a confidential, anonymous report either by telephone or the Internet. To report a concern by phone you will speak with a NAVEX Communication Specialist who will ask you for several items of information, document your feedback, and ask follow up questions for clarification. This process will take around 10 to 15 minutes. The Internet or web intake process will walk you through a similar set of questions. In both cases, upon completion of your report the case information will be routed to Huntsman Ethics and Compliance for further review and investigation. Concerns reported through Speak Up are handled the same as those reported directly to the company.
Speak Up is NOT an emergency service. Do not use this site to report events presenting an immediate threat to life or property. If you require emergency assistance, please contact your public emergency services.
What type of situations should I report?
The purpose of Speak Up is to document concerns about suspected or potential violations of law, violations of Huntsman Business Conduct Guidelines, policy, or other workplace misconduct. This includes: acts of corruption and bribery, conflicts of interest, acts of dishonesty and deceptive practices, inappropriate conduct, discrimination, harassment, and retaliation, data security and privacy breaches, misuse of computer or electronic communications, and concerns about environmental health and safety issues, antitrust, and securities laws.
Are other ways I can report concerns besides Speak Up?
Absolutely. Ideally, you should bring any concerns forward to your direct manager, or other members of our Management Team. However, reports can be made through several channels including Human Resources, local Facility Compliance Officers (FCOs), Compliance Champions, Legal, Internal Audit, or directly to Ethics and Compliance at ethics@huntsman.com.
If you are not sure if what you observed or heard is a violation of company policy, or involves unethical conduct, feel free to contact any of the resources above to discuss the situation and help determine the appropriate next steps. You can also consult Huntsman Business Conduct Guidelines for further information.
Why should I report what I know?
The reputation of Huntsman is built upon the actions of everyone who acts on behalf of our Company. Huntsman’s success, good name, and reputation are due to the integrity, honesty, and dedication of our associates. Protecting our reputation and values is fundamental to our continued growth. We are all expected to ensure that our conduct remains true to our values of Honesty, Integrity, Respect, and Responsibility. Speaking up helps stop or prevent illegal or ethical misconduct from occurring.
Furthermore, we strive to create a positive, productive business environment and critical to this is acting in an ethical manner and informing the company if behavior is occurring that is inconsistent with our corporate values.
What if I remember something important about the incident after I file the report? What if the company has further questions for me concerning my report? How do I find out the status of my concern?
When you file a report through Speak Up you will be issued a report key. Please record it and keep it in a safe place. You will need to use this report key along with the password of your choosing to return to Speak Up. You can access Speak Up again through the website or telephone hotline to receive feedback or provide additional information about your concern. We strongly suggest that you check back into Speak Up if you are an anonymous reporter as this is the only way we will be able to communicate with you if we have any questions.
You can also check the status and disposition of your report by accessing Speaking Up. Due to privacy concerns it is not Huntsman’s practice to disclose detailed findings or case outcomes to reporting parties. We will, however, be able to share with you whether the case is still under investigation or has been closed. You are, of course, encouraged to report any feedback or continuing issues even after case closure.
Reporting Security & Confidentiality
Where do these reports go and what happens to the information provided?
Speak Up reports are entered directly in the NAVEX secure server to prevent any possible breach in security. NAVEX makes these reports available only to specific individuals within Huntsman Ethics and Compliance who are charged with evaluating the report based on the type of violation and location of the incident. The report will then be assigned to a trained investigator for further investigation.
Any information you provide will be treated as confidential to the extent permitted by law and other than where disclosure is necessary in the context of an investigation into a reported concern. Confidentiality will be protected to the greatest extent possible while allowing for a thorough investigation and appropriate resolution to take place.
Non-Retaliation Policy and Anonymity
You can choose to make a report by identifying yourself or make a report anonymously, except where legally restricted from doing so. With our principle of non-retaliation, we encourage you to identify yourself when making a report because knowing the identity of the reporting party can often assist with the investigation. We take our non-retaliation policy very seriously as it key to the success of our program. No one who reports any suspected violation in good faith will be subject to retaliation for making such a report. “Good faith” means that you come forward with all of the information you have and believe you are giving a sincere, truthful, and complete report.
Please include sufficient details to enable Huntsman to complete a thorough review of your report, especially if you chose to report anonymously.
Can I file a report from a home, company or alternative computer and still remain anonymous?
The Speak Up service provider, NAVEX, does not generate or maintain any internal connection logs with IP addresses, so no information linking the PC you use to file the report is available. In fact, NAVEX, is contractually committed not to pursue a reporter’s identity.
A 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 system strips away Internet addresses so that anonymity is totally maintained.
Is the telephone 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 Speak Up site. These reports have the same security and confidentiality measures applied to them during delivery.