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Hearthside Food Solutions, LLC Compliance Hotline

SEE SOMETHING, SAY SOMETHING

HEARTHSIDE FOOD SOLUTIONS COMPLIANCE HOTLINE OVERVIEW

The hotline, including online intake or by phone, is one of our speak-up channels to raise concerns about ethical issues and potential misconduct.

Who operates the hotline?

NAVEX, an independent third party, operates the hotline.

Why do we have the Hearthside Food Solutions Compliance Hotline?

Hearthside is committed to creating and maintaining an environment where anyone can raise concerns about ethical issues and potential misconduct without fear of retaliation. Like many companies, Hearthside provides the Hearthside Food Solutions Compliance Hotline as an optional service for employees to speak up.

We hope that you always feel free to discuss questions and concerns with your manager or HR. If you feel uncomfortable asking questions or expressing concerns to management, though, the hotline provides an additional way to receive help.

When should I use the Hearthside Food Solutions Compliance Hotline?

Use the hotline if you have concerns about ethical issues and potential misconduct. Alternatively, you could raise your concern through your management, HR or Legal. Your decision to use the hotline is voluntary.

ETHICAL CONDUCT CONCERNS

What is an ethical concern or issue?

An ethical issue includes any actual or suspected breach of Hearthside Food Solutions policies and any other improper or illegal conduct.

The hotline does not cover employee grievances, complaints relating to job performance, or the terms and conditions of employment. These issues are not complaints that relate to potential malpractice or material misconduct.

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

We all have the right to work in a positive environment. With that right comes the responsibility of acting ethically 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 want me to raise my concerns?

Yes. Hearthside Food Solutions requires employees to raise concerns as soon as they become aware of potential misconduct. Raising a concern can minimize the possible negative effect on Hearthside and our people regarding financial, legal or reputational risks and health and safety threats.

Should I raise the concern first with my manager, HR or Legal?

If you are unsure whether the concern is justified and you feel comfortable contacting your management, HR or Legal, please do so. Contact the hotline if you do not feel comfortable raising the concern with your manager or management, and HR or Legal confirms that your concern could be an ethical issue or potential misconduct.

What if my manager or other managers are involved in a concern?

The EthicsPoint system and distribution protocols are designed so any individuals named in the report are not notified about or granted access to reports in which they have been named.

Can I get in trouble for using the Hearthside Food Solutions Compliance Hotline?

No. Hearthside provides the hotline for your use and protection. Retaliation against anyone who raises an ethical concern in good faith is unacceptable and almost always against the law. If a reporter informs Hearthside about retaliation, Hearthsdie takes this seriously and investigates. Hearthside will discipline anyone who engages in retaliation for reporting an ethical concern.

CONFIDENTIALITY

Is the Hearthside Food Solutions Compliance Hotline secure?

Yes. Your concern or question is entered directly onto the EthicsPoint server over a secured connection. EthicsPoint’s servers do not connect to Hearthside's information technology systems.

May I remain anonymous?

You may remain anonymous in all countries except those that prohibit anonymous reporting. In the United States you may remain anonymous. Although it may be easier in many cases to address your issue by identifying yourself, you are not required to do so. If you remain anonymous, EthicsPoint or Hearthside will not make an effort to identify you.

Can I communicate with the investigators while remaining anonymous?

Yes. When you report a concern via the hotline, the system will provide a report key and prompt you to select a password.

Store the report key and password in a safe place. With this key, the investigators can maintain communication with you. They, or you, could ask for further information and provide feedback to you where necessary.

SPEAK-UP: ONLINE OR PHONE

How do I use the Hearthside Food Solutions Compliance Hotline?

The hotline has two methods of intake. With EthicsPoint, you can raise a concern in confidence by web intake or by telephone. Choose one channel, do not duplicate the report by using both channels.

Web intake portal

The first channel is the intake portal. The intake form consists of questions to identify the relevant details of your concern or question and is to understand:

  • what happened,
  • who are involved,
  • where and when did it happen and;
  • how did it happen.

The web intake portal is available 24 hours a day, seven days a week, every day of the year. You may access it from any computer that has an internet connection.

If you have documents, photos, recordings or videos, you could upload to the web intake portal.

Toll-free telephone by country

The second channel is a toll-free telephone number by country. This service is available 24 hours a day, seven days a week, every day of the year. A professionally trained EthicsPoint operator will guide you through a series of questions to identify the relevant details of your concern or question to understand:

  • what happened,
  • who are involved,
  • where and when did it happen; and
  • how did it happen.

The operator will also ask you to provide supporting documentation, if available. If you have documents, photos, recordings or videos, you could upload them to EthicsPoint after you complete the report, and the system generates the encryption key.

At the conclusion of the call, the operator will summarize the information you have submitted and make any necessary changes to ensure that you are satisfied with the accuracy of your question or concern.

May I partially complete the form and return to complete it later?

No. If you close your internet browser while completing the form, the EthicsPoint web intake portal will not save the information you have entered, so choose a time and place to use the system to complete the form.

What information do I need to provide?

Provide information in as much detail as possible. Details should include the who, what, when, where, why, and how concerning the allegation(s) raised. If possible, you can attach evidence such as documentation or emails that help substantiate your claim(s). Reports that do not reasonably satisfy conditions of completeness may not be reviewed or investigated further.

ETHICAL CONDUCT QUESTIONS AND INVESTIGATION PROCESS

What happens when I raise a concern?

Whether made by web intake or telephone, all concerns are reviewed promptly by a professionally trained EthicsPoint intake specialist. The EthicsPoint intake specialist will send a report to the designated HR professional responsible for managing and following up on your report.

The appointed employee will start the investigation if you provide sufficient details.

If necessary, Hearthside will take appropriate remedial action while the investigation is ongoing. Those responsible for following up on your matter are trained professionals who handle the issue with discretion.

All reports, through web intake or telephone, are entered into a database for recordkeeping and case management.

Do I receive confirmation of my report? What is the timeframe of confirmation?

Yes. You receive a confirmation that your report has been received, usually within one to seven business days. After the conclusion of the investigation, you will receive a message notifying you that the investigation has been closed. The email will indicate that all appropriate actions, if or where necessary, have been taken. You do not receive details about the investigation for confidentiality reasons.

FOLLOW-UP ON REPORTED CONCERNS

What if I remember something important about the incident after completing the intake form?

When you raise a concern, either using the web or by telephone, the system will provide a report key and prompt you to select a password.

With the report key and password, you can return to the EthicsPoint system by Internet or telephone and access the original report. At that point, you can add more details.

How will I receive information on the status of my case?

The system will provide a report key and prompt you to select a password. Record the report key and password and keep them in a safe place. Use your report key and password to re-contact EthicsPoint to check on the status of your case, provide more information, or answer follow-up questions from those investigating the matter.

If I remain anonymous, how can investigators contact me for a follow-up?

When given your report key and password, you can follow up with EthicsPoint by telephone or web, even if you report anonymously. If an investigator wants to contact you regarding your concern, the investigator can leave you a message or ask you a question through EthicsPoint.

What should I do if I lose my report key or password?

Because of the confidentiality level maintained for reports, the process requires you to file a new report if you lose your report key or password. You can mention in the latest report that this matter relates to another report you filed earlier.