DATA PROTECTION & PRIVACY NOTICE

The data privacy regulations of some countries require that a person making a report containing personal data must be notified of certain collection and retention practices regarding the information submitted by that person through this helpline service.

If you do not wish to accept the terms below, we may be unable to accept any information through this helpline system and suggest you report this matter directly to your supervisor or manager or to a representative of the Human Resources, Legal or Global Compliance and Employee Relations Departments, depending on the nature of the possible violation.

  • 1. General

    The Herman Miller Ethics and Compliance Hotline (“hotline”) is a web and phone-based intake system provided by Herman Miller Group located at 855 E. Main Avenue, Zeeland, MI 49464 (“Herman Miller”) to its employees, vendors, suppliers and business partners and those of its subsidiaries (“Reporters”) for reporting suspected violations of laws or regulations, or company policies related to financial, accounting, auditing and bribery matters.

    You may contact Herman Miller with any questions relating to this Notice or this service as follows:

    Email: ethicsandcompliancehotline@hermanmiller.com

    For more information click here.

    In certain countries, such as the United States, the hotline may also be used to report suspected violations of other matters. It and the database in which the personal data and information that you may report is stored, are operated in the United States by NAVEX Global.

  • 2. Use of the hotline

    Use of the hotline is entirely voluntary. You are encouraged to report possible violations directly to your supervisor or manager, or to a representative of the Human Resources, Legal or Global Compliance and Employee Relations Departments, depending on the nature of the possible violation. If you feel that you are unable to do so, you may use the hotline to make your report.

    For more information click here.

    The hotline is a confidential online reporting system that allows you to report suspected violations of law or company policies, as well as other concerns you may have, to Herman Miller. In certain countries, Herman Miller may only accept reports through the hotline that relate to financial, accounting, auditing, bribery, competition law, discrimination and harassment and environment, health, hygiene, and safety matters. If your concern pertains to a matter that, under local law, may not be accepted by Herman Miller through the hotline, you will need to contact your supervisor or local management or a representative of the Human Resources, Legal or Global Compliance and Employee Relations Departments to report the matter.

    Please be aware that the information you supply about yourself, your colleagues, or any aspect of the company’s operations may result in decisions that affect others. Therefore, we ask that you only provide information that you believe is true. You will not be subject to retaliation from Herman Miller for any report of a suspected violation that is made in good faith, even if it later turns out to be factually incorrect. Please be aware, however, that knowingly providing false or misleading information will not be tolerated. The information you submit will be treated confidentially except in cases where this is not possible because of legal requirements or in order to conduct an investigation, in which case the information will be handled sensitively. We encourage you to identify yourself in order for us to follow up with questions we may have.

  • 3. What personal data and information is collected and processed?

    The hotline captures the following personal data and information that you provide when you make a report: (i) your name and contact details (unless you report anonymously) and whether you are employed by Herman Miller; (ii) the name and other personal data of the persons you name in your report if you provide such information (i.e.: description of functions and contact details); and (iii) a description of the alleged misconduct as well as a description of the circumstances of the incident. Note that depending upon the laws of the country in which you are residing, the report may not be made anonymously; however, your personal information will be treated confidentially and will only be disclosed as set out below.

  • 4. How will the personal data and information be processed after your report and who may access personal data and information?

    The personal data and information you provide will be stored in a database which is located on servers hosted and operated in the United States by NAVEX Global. NAVEX Global has entered into contractual commitments with Herman Miller to secure the information you provide in accordance with applicable law. NAVEX Global is committed to maintaining stringent privacy and security practices including those related to notice, choice, onward transfer, security, data integrity, access, and enforcement.

    You may contact Herman Miller with any requests relating to the use, transfer, correction, or deletion of any of your personal data stored by this service at:

    Email: ethicsandcompliancehotline@hermanmiller.com

    For more information click here.

    For the purpose of processing and investigating your report and subject to the provisions of local law, the personal data and information you provide may be accessed, processed and used by the relevant personnel of Herman Miller, including Human Resources, Finance, Business Risk/Internal Audit, Legal, Global Compliance and Employee Relations, management, external advisors (e.g. legal advisors), or, in limited circumstances, by technical staff at NAVEX Global. Those individuals may be located in the United States, the United Kingdom or elsewhere.

    Personal data and information you provide may also be disclosed to the police and/or other enforcement or regulatory authorities. The relevant bodies that receive and process personal data can be located in the US or in another country that may not provide the level of data protection available in the EU.

    The personal data you provide will be kept as long as necessary to process your report, or, if applicable, as long as necessary to initiate sanctions or to meet our legal or financial needs.

  • 5. Accessing information concerning the report

    Herman Miller will promptly notify any person who is the subject of a report to the hotline except where notice needs to be delayed to ensure the integrity of the investigation and preservation of relevant information.

    For more information click here.

    With some exceptions, the subject of the report may access information concerning the report (with the exception of the identity of the reporter) and request correction of personal data that is inaccurate or incomplete in accordance with applicable law. Similarly, with some exceptions, reporters may also access information about the report and request corrections of their personal data in accordance with applicable law. To make any such corrections, please contact the General Counsel or the Global Compliance Executive.

  • 6. Special Country Regulations

    Throughout much of the European Union and surrounding areas, reports may be limited in topics, generally to concerns about accounting, auditing, bribery, competition law, discrimination and harassment and environment, health, hygiene, and safety matters. Further, some countries restrict reports such that only employees in key or management functions may be the subject of a report.

    For more information click here.

    Any issues or concerns relating to topics not permitted by law to be reported via the hotline should be reported directly to your Manager or Supervisor or a representative of the Human Resources, Legal or Global Compliance and Employee Relations, Business Risk/Internal Audit or by emailing ethicsandcompliancehotline@hermanmiller.com as appropriate for the subject matter of the possible violation. In some countries, anonymous reports may not be permitted under the law except under extremely restrictive circumstances.