Frequently Asked Questions

About EthicsPoint

Reporting - General

Reporting Security & Confidentiality

Tips & Best Practices

Issue Categories and Sub-Categories with Descriptions

About EthicsPoint

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting system created and supplied to Nidec by NAVEX to assist management and employees to work together 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?

• Our employees are important to us. By creating open channels of communication, we can promote a positive work environment and maximize productivity.
• Many laws require all companies to provide reporting channels, most with the ability to remain anonymous, for financial fraud and other types of compliance, legal and ethical concerns.
• We have chosen to meet and exceed these requirements by using EthicsPoint for our employees in the Americas and EMEA regions as well as in the Asia region for the MOEN and ACIM business units. 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 report via either the telephone or the Internet.

What type of situations should I report?

The EthicsPoint system is designed for employees and others to report any violation of the Nidec Code of Conduct, the Employee Ethics Handbook, or other serious concern you may have such as a violation of law. A list of the issue categories and subcategories is available at the end of these FAQs for reference, including descriptions of each.

If I see a violation, why not 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 the Nidec Code of Conduct, the Employee Ethics Handbook or the law, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager, or other member of our management team. Talking with a leader or HR representative at your location is a great first step. If neither are available, or you do not feel comfortable doing so, you can utilize the EthicsPoint telephone number or website.

Why should I report what I know? What is in it for me?

Reporting inappropriate conduct or actions leads to a more positive work environment. By working together, we can maintain a healthy, appropriate and productive workplace. Corporate misconduct can threaten the livelihood of an entire company.

Does management really want me to report?

Yes, 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, and 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. EthicsPoint makes these reports available only to specific individuals within the company who are charged with evaluating the report. Each of these report recipients has had training in keeping these reports in the utmost confidence.

Is this system just an example of someone watching over me?

No, the EthicsPoint system allows Nidec to provide employees and others with a safe, secure, confidential (and, where applicable, anonymous) means to report matters of concern, and to seek guidance on ethical dilemmas. Effective communication is critical in today’s workplace and this is a great way to enhance that communication.

We have carefully chosen the best reporting system to meet our compliance obligations while maintaining a simple reporting environment.

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 will this log identify me as a report originator?

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 data from NAVEX shows that fewer than 12% of reports are generated during business hours.

The EthicsPoint system does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available. In fact, NAVEX is contractually committed not to pursue a reporter’s identity.

Can I file an anonymous report from home?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous if you have chosen to report anonymously. Your screen name or other personal identifiers will not be identified by the EthicsPoint system and the EthicsPoint system does not log IP addresses so that anonymity is totally maintained. Plus, NAVEX is contractually committed not to pursue a reporter’s identity.

I have chosen to report anonymously but 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 anonymity if you have chosen to report anonymously. 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 with the company…”.

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 with 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 does not 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.

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 would rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you were not sure.

What if my boss or other managers are involved in a violation? Will 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 using the EthicsPoint online system or through the EthicsPoint Call Center, you receive a unique user name and are asked to choose a password. Your access number and password is known only to you and is not something the Compliance team has the ability to view, reset, or look up should you not remember it. 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 EthicsPoint system in the time specified to answer company questions. You and the company now have entered into a “confidential dialogue,” where situations are not only identified, but can also be resolved, no matter how complex. By following up and providing more information, it allows us to fully review your report and help to address the concern appropriately. Being an active participant is important to having your concern resolved.

Are these follow-ups on reports as secure as the first one?

All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

Can I still file a report if I do not 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 do not 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.

Issue Categories and Sub-Categories with Descriptions

Issue Category	Issue Sub-Category	Definition/Standard
Honest & Accurate Financial & Other Information	Accounting, Auditing and Financial Reporting	Reports related to accounting, financial reporting or auditing. Examples include the unethical or improper recording and analysis of the business and financial transactions associated with generally accepted accounting practices. Examples include misstatement of revenues, misstatement of expenses, misstatement of assets, misapplications of GAAP/IFRS principles, and wrongful transactions.
Honest & Accurate Financial & Other Information	Compliance with SOD and DOA	Reports related to Segregation of Duties (SOD) and Delegations of Authority (DOA) rules. Examples include failure to obtain the proper levels or multiple levels of approvers for transactions or other matters that require separate or multiple reviews or ignoring established processes for RINGI approvals and the splitting of projects to lower the approval levels. Also includes the failure of Accounting and Finance employees to identify and notify the company when this is detected.
Honest & Accurate Financial & Other Information	Confidential and Proprietary Information	Reports related to confidential and proprietary information or intellectual property. Confidential information is any non-public information that is not intended or permitted to be shared beyond those with a genuine business need to know the information. Confidential information can include information about people or companies and specifically includes business plans, trade secret information, customer lists, sales and marketing strategies, pricing, product development plans, and any notes or documentation of the foregoing. Intellectual property refers to an original, intangible creation of human intellect that is legally protected from unauthorized use. Intellectual property includes patents, trademarks and copyrighted works of authorship, like photographs, music, literary works, graphic design, source code, and audio and audiovisual recordings.
Business Integrity & Ethical Practices-	Bribery and Corruption	Reports of public or private instances of bribery. Bribery occurs when a person offers money or something else of value – to an official or someone in a position of power or influence – for the purpose of gaining influence over them. Corruption includes dishonest or illegal behavior – especially of people in authority – using their power to do dishonest or illegal things in return for money or to get an advantage over someone else.
Business Integrity & Ethical Practices-	Conflicts of Interest	Reports about a conflict of interest, either a self-report or a report involving the behavior of others. A conflict of interest can arise in any situation where an employee's financial or personal interest could potentially or actually interfere, or even appear to interfere, with their business judgement or the interests of the organization.
Business Integrity & Ethical Practices-	Free and Fair Competition	Reports involving activities that undermine free and fair competition in the marketplace. These activities frequently involve any agreement with a competitor to fix prices or otherwise limit competition. Even the appearance of such agreement is problematic.
Business Integrity & Ethical Practices-	Human Rights	Reports related to human rights which generally refer to the basic rights and freedoms of individuals. Examples include reports relating to human trafficking or modern slavery that involve the use of force, fraud or coercion to obtain labor or sex for money, drugs or other goods.
Business Integrity & Ethical Practices-	Insider Trading	Reports that a person is buying or selling any company's (employer's or any other company's) securities and/or stock based on non-public information as well as passing (tipping) this information on to someone else who then buys or sells stock.
Business Integrity & Ethical Practices-	Misuse or Misappropriation of Assets	Reports that the organization's assets are being wasted, inappropriately used, abused, or not properly protected. This category can include a wide array of assets such as property, tools, money, credit cards, facilities, company vehicles, employee time, and even abuse of employer provided benefits.
Business Integrity & Ethical Practices-	Other Business Integrity	Reports related to business integrity that cannot be categorized elsewhere. Examples include industry specific policies, regulations or laws.
Business Integrity & Ethical Practices-	Supply Chain DD	Reports related to supply chain due diligence which generally refers to both the responsibilities and practices of the company in conducting due diligence before contracting with third party suppliers and the responsibility of the company to monitor those suppliers with reference to regulatory and other global corporate responsibility principles. Examples include reports relating to qualification and monitoring of third parties for ethical and compliant practices.
Safety & The Environment	Environmental	Reports about impact to the environment. This could include intentional, negligent or accidental acts or omissions that harm the environment or violate policy or regulatory or legal requirements. It can also include acts or omissions that otherwise present a risk to the climate. Examples can include such things as spills, mismanaged wastewater or resources, release into the atmosphere of harmful materials or substances, or improper disposal of hazardous waste.
Safety & The Environment	Health and Safety	Reports about workplace safety. This can include employee safety and facilities or equipment. Each employee is responsible for maintaining a safe and healthy workplace for all employees by following safety and health rules and practices and reporting accidents, injuries and unsafe equipment, practices or conditions. Reports about physical security in a facility.
Safety & The Environment	Imminent Threat to a Person, Animals or Property	Reports of imminent or immediate threat of harm to a person or people, animals or property. Reports may or may not involve a weapon and generally are the kind of incident where authorities (such as police or fire) are called to assist.
Safety & The Environment	Product Quality and Safety	Reports about quality and safety issues related to products. Examples include allegations that a product is not safe for intended use, is putting others at risk of harm, or that it fails to meet industry standards.
Safety & The Environment	Substance Abuse and Drug Free Workplace	Reports related to impairment resulting from use of substances (such as drugs or alcohol, whether legal or illegal) that impact the workplace or violate a policy. The activity can include on- or off-duty and on- or off-premises conduct.
Personnel or Workplace Concerns	Compensation and Benefits	Reports related to matters of compensation, pay, insurance, time-off, retirement benefits, leaves of absence (paternity, maternity, other medical) and other common employee benefits. Examples include incorrect paycheck or inaccurate recording of vacation, time-off and sick time.
Personnel or Workplace Concerns	Discrimination	Discrimination includes (1) reports relating to accommodation requests or (2) reports relating to a negative employment action impacting a term or condition of employment, that action is taken by the employer (which can include managers as well as others who have control over terms or conditions of work such as team leads), and the action was taken because of a protected characteristic. Also included can be discriminations of specific laws or regulations, including laws associated with gender pay gaps and civil rights. A workplace accommodation involves a request to adjust something relating to work linked to either a religious practice or belief or a disability. This includes allegations or reports related to religious practices or beliefs or speaks to a workplace modification or leave request linked to a medical condition or disability.
Personnel or Workplace Concerns	Harassment, Sexual Harassment	Reports of harassment that are linked to a protected characteristic (such as race, gender, sex, religion, disability, age, etc.) and includes allegations of unwelcome behavior that is offensive to a reasonable person, and is related to, or done because of, a protected characteristic.
Personnel or Workplace Concerns	Political Activity and Labor	Reports of improper use of employer resources (time, assets, brand, etc.) for political activity (by an individual or an organization) such as using work time for political activities, pressuring colleagues to give money or time to a PAC or associating organization name with a political candidate, official, or group. It can also include misuse of company funds for political activities, using company resources to create or distribute political messages and violations of lobbying regulations and restrictions. Also includes other labor activity or matters that are more political in nature or governed by labor relations boards, acts, or similar agencies, and social media concerns.
Personnel or Workplace Concerns	Retaliation	Reports of retaliation (including claims of reprisal or victimization) of any kind against an employee including claims of any action taken to punish or dissuade an employee from making a report or participating in an investigation either internally or externally. Retaliation claims most often involve allegations against a manager, supervisor or some other person with control and power over the reporting person. However, retaliation can also involve conduct by a coworker.
Personnel or Workplace Concerns	Workplace Civility – Unprofessional Behavior	Reports related to favoritism, unfair treatment, inappropriate behavior, unprofessional behavior, and disrespectful behavior connected to work that are not harassment or discrimination and that also do not rise to the level of abuse or bullying.
Personnel or Workplace Concerns	Other Human Resources Issue	Reports that cannot be categorized elsewhere and likely involve Human Resources. Examples include performance management, discipline, immigration, labor relations, grievances, job eliminations, arrests and convictions, and the sale or distribution of drugs.
Personnel or Workplace Concerns	Workplace Civility - Bullying	Reports related to abusive or bullying behaviors connected to work that are not harassment or discrimination.
Other Compliance with Policy & Law-	Data Privacy and Protection	Reports related to the rights and responsibilities relating to data held or processed by an organization. This data can include information about employees, customers, consumers, or others. Examples include allegations of data misuse, loss or theft of data, breaches or attempted breaches, or requests by an individual relating to their own data (DSRs).
Other Compliance with Policy & Law-	Global Trade	Reports related to the import and export of goods and services globally. It can include imports (bringing goods or services into a country) or exports (sending goods or services - including software - from one country to another). This category also includes reports relating to sanctions such as trade sanctions, which make it unlawful to do business with sanctioned people or countries.
Other Compliance with Policy & Law-	Other	Reports that do not fit any of the other categories listed.
Inquiry	Inquiry - Other	Other questions or inquiries submitted through hotline channel, such as "Ask a Question"
Inquiry	Disclosure - Gift	Disclosure of gifts and entertainment (received or given) for review and decision
Inquiry	Disclosure - Conflict of Interest	Disclosure of potential or actual conflicts of interest for review and decision
Inquiry	Third Party Requests	Requests by third parties to complete questionnaires, provide documentation, adopt or execute Code of Conduct, etc., for purposes of ensuring supplier due diligence on their part or our company's part, as well as compliance requests related to supply chain due diligence or human rights legislation.