About Integrity Helpline

Reporting – General

Reporting Security & Confidentiality

Tips & Best Practices

About Integrity Helpline

What is the Integrity Helpline?

The Integrity Helpline is a user-friendly telephone and web-based resource that our work force, business partners, vendors and others can use to ask questions or report actual or potential violations of the law, eBay’s Code of Business Conduct and Ethics or other eBay policies. The Integrity Helpline is operated by NAVEX, an independent third-party that provides Helpline services to many global companies like eBay.

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX to assist management and employees work together in addressing fraud, abuse, and other misconduct in the workplace, all while cultivating a positive work environment. For internal reference, eBay has rebranded this tool as Integrity Helpline.

Why do we need a system like Integrity Helpline?

• 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 our other efforts to foster a culture of integrity and ethical decision-making.

How do I contact the Integrity Helpline?

People can ask a question or make a report on the Integrity Helpline by filling out an online form or by making a toll-free telephone call seven days a week, twenty-four hours a day, from any location, in multiple languages. The toll-free telephone numbers for your country are located on this website. You do not need an eBay computer or company email address to use this website.

Reporting – General

May I report using either the Internet or the telephone?

Yes. With Integrity Helpline, you have the ability to file a confidential, anonymous report via either the telephone or the Internet.

How does the Integrity Helpline Work?

If you ask a question or make a report on the Integrity Helpline by telephone, a NAVEX operator will ask you some questions to gather as much information as possible. You can also log into the website and fill out an online form which is available in multiple languages. If the form is not available in your language, call the toll-free number and interpreters who speak over 48 languages will be able to help you.

When submitting your question or report on the Integrity Helpline, you will create a password and be given a unique report number. The information you provide will be sent to eBay’s Office of Ethics and Compliance for an initial assessment and will then be assigned to an authorized investigator depending on the nature of the report. You can follow-up and check the status of your question or report by simply calling back or logging onto the website with your password and report number.

What type of situations should I report?

You should contact the Integrity Helpline if you have any questions or concerns about potential violations of the law, our Code of Business Conduct and Ethics, and other eBay policies.

Please note there are restrictions on the types of categories that can be reported through the Integrity Helpline by employees in the European Union. If the Integrity Helpline cannot accept a question or report about your concern, eBay encourages you to talk with your manager or a higher-level manager in your reporting line, contact an eBay Business Ethics Officer.

If I see a violation, shouldn't I just report it to my manager, security, or people experience and let them deal with it?

If you prefer, you may initially report a violation or potential violation of the law, our Code of Business Conduct and Ethics, or other eBay policies to your manager or a higher-level manager in your reporting line.

If you are uncomfortable reporting to management, if you do not know whom to contact, or if you believe your concern has not been satisfactorily addressed, please proceed to submit a report through the Integrity Helpline. With the Integrity Helpline, you can be sure that your issue or question is routed to the proper people. And lastly, all report information is secure and is treated as confidential to the extent reasonably possible.

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

All of our actions collectively determine our company’s success. By reporting your concerns, you help build a company where integrity matters in everything we do.

Does management really want me to report?

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. Also, offering positive input 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 to prevent any possible breach in security. EthicsPoint makes these reports available only to specific individuals within the company who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports in the utmost confidence.

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

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. 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.

What should I do if I lose my report key or password used for submitting a report?

Because of the high level of security that is maintained for these reports, if you lose your report key or password, you will need to fill out a new report. You should mention in the new report that it is related to a report you previously submitted.

Should I submit a report on the Helpline if I just need to ask a question?

If you are in any doubt about the best course of action or if you have any question concerning compliance with our Code of Business Conduct and Ethics, any eBay policy or the law, eBay encourages you to talk with your manager or higher level manager, My HR or a Business Ethics Officer. If you are in doubt about the interpretation or application of any law or regulation, you are encouraged to contact the Legal Department.

Now, if you prefer, you can also use our Integrity Helpline to ask any question you may have about the best course of action in a particular situation or if you have any question concerning or compliance with eBay’s Code of Business Conduct and Ethics, any eBay policy or the law.

What if I am not sure if I am reporting activity that is a violation?

You should still make the report. The Integrity Helpline is a resource to ask a question or make a report about a situation that simply may not feel right. By using the Integrity Helpline, you can make sure that your questions get to the right people so that you get the answers that you need. You should never try to investigate or confirm issues themselves as it could compromise the investigation process.

What if I want to report a violation by a member of the Office of Ethics and Compliance or a Business Ethics Officer?

If the possible violation or concern involves a member of the Office of Ethics and Compliance or a Business Ethics Officer, you may report it to any other Business Ethics Officer, who will exclude the identified member from all consideration, investigation and resolution of the issue. You may also report it directly to a C-level executive, the Vice President of eBay Internal Audit, or the eBay Board of Directors.

What if I think my manager or other member of management is involved in a violation, should I still make the report using the Integrity Helpline?

Yes, you should still make the report. Our standards apply to all eBay employees regardless of their position within eBay. Unlawful or unethical behavior can cause harm to employees, our business or our reputation. Our leaders and managers have a responsibility to be role models by demonstrating ethical behavior at all times.

So, what are the different ways to make a report of a violation?

eBay encourages the active detection and prevention of misconduct. If you have reason to believe that any employee or party acting on behalf of eBay – including your manager or any member of senior management - has violated, may violate, or is acting in a manner that appears to violate our Code of Business Conduct and Ethics or compliance with the law or eBay policies you are expected to immediately report such activity to at least one of the following resources:

• The Integrity Helpline,
• Your manager or a higher-level manager in your reporting line,
• Any eBay Business Ethics Officer.

Will the company really do anything about a report I make on the Integrity Helpline?

Yes. eBay takes all reports and allegations seriously and devotes the appropriate time and resources to investigate them. If the information you provide is proven and a violation of the law, the Code of Business Conduct and Ethics, or other eBay policy has occurred, appropriate corrective action will be taken.

Will I ever hear anything about the outcome of a report that I make on the Integrity Helpline?

eBay treats each report in a professional and confidential manner consistent with our commitment to investigate the information and our obligation to comply with applicable laws and regulations. After an investigation, the company will update the status of a report when a case has been closed. However, due to confidentiality concerns, we do not report the details of our investigations or any resulting disciplinary action.

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.

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 EthicsPoint’s data shows that fewer than 12% of reports are generated during business hours.

Can I file a report from home and still remain anonymous?

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 EthicsPoint system strips away Internet addresses so that anonymity is totally maintained. Plus, EthicsPoint is contractually committed not to pursue a reporter’s identity.

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. 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…”.

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.

What if I am afraid of being retaliated against for making a report on the Integrity Helpline?

The ability to openly ask questions or communicate ethics and compliance concerns without fear of retaliation is essential to the success of our Ethics & Compliance program. eBay will not tolerate any retaliation whatsoever against any person for asking questions or raising concerns in good faith. If you feel that you have experienced any form of retaliation as a result of making a report or raising an issue, promptly report it just as you would any other inappropriate behavior.

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?

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'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you weren't sure.

What if my boss or other managers are involved in a violation? Won’t 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 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 company 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 company questions. You and the company 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-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 don’t 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 don’t 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.

What if I remember something important about the incident after I have submitted a report through the Integrity Helpline? How can I provide that information?

When you submit a report in the Helpline portal or through the Integrity Helpline phone numbers, you receive a unique user name and are asked to choose a password. You can return to the Integrity Helpline again either by Internet or telephone and access the original report to answer questions or add further information.

All original reports submitted by the internet or telephone can be accessed in the original language via the internet. If you submitted an original report by the telephone in a language other than English, you will only be able to access it via telephone in English. In general, when submitting reports or questions in languages other than English, we suggest you do so by the Internet if you want to access the original report in your local language.