About EthicsPoint

What is EthicsPoint?

EthicsPoint is a tool created by NAVEX that allows you to make a confidential and, if you wish, anonymous report. Graco has chosen to use it to assist employees, distributors and others to report suspected fraud, abuse, workplace misconduct or other violations of Graco’s Code of Ethics and Business Conduct.

How and What to Report

May I report using either the Internet or the telephone?

Yes. With EthicsPoint, most people have the ability to file a confidential, anonymous report via either the telephone or the Internet. Reporting by telephone is not available in all countries, but you may file an online report from any location.

What type of situations should I report?

Please report any violation of Graco’s Code of Conduct, or any other unethical or unlawful incident or activity relating to Graco, its employees or business practices that you are aware of or have reason to believe may exist.

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. NAVEX 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.

Can I use EthicsPoint to report my concern if I am a Graco employee?

Yes. When you observe behavior that you believe violates Graco’s Code of Conduct, we ask that you report it. Ideally, you should bring any concerns forward to your direct manager, your HR representative or other member of our management team. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that we have partnered with NAVEX. We would rather you report anonymously than keep the information to yourself.

Does management really want me to report?

We do. In fact, it’s helpful to Graco for you to report. You may have initial knowledge of an activity that could be cause for concern. Your reporting can minimize the potential negative impact on the company and our people. You may also help identify issues that can improve our culture of integrity and ethical decision-making, which Graco firmly believes is essential to our productivity and performance as a company.

The report issue types seem very complicated! What if I don’t know how to classify my report?

It’s helpful to Graco if you can file under one of the issue types, if one is applicable to your concern. Click on “Details” to the right of the issue type to see a description. If you are not sure or don’t see an issue type that fits, please select “Other.”

Security & Confidentiality

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPoint secure server. NAVEX makes these reports available only to specific individuals within Graco.

Isn’t it true that any report I send from a company computer generates a log that shows every web-site that my PC connects with, and won’t this log identify me as a report originator?

NAVEX does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available.

I am concerned that the information I provide EthicsPoint will reveal my identity. How can I be sure that won’t happen?

Graco has been assured by NAVEX that the EthicsPoint system is designed to protect your anonymity. A report from any computer or Internet portal, whether made at work, from home or another location will remain anonymous because a visitor to the site is not identified by screen name, and the system strips away Internet addresses. Take care, however, that your report does not accidently reveal any information that could identify you.

Is the telephone toll-free hot line confidential and anonymous?

Yes. The interviewer who takes your call will ask you questions and will create a written report for you. They will ask if you wish to remain anonymous and if so, they will not ask for identifying information. These reports will be delivered to Graco in the same way and with the same security and confidentiality measures as with an online report. The hot line is available 24 hours a day, 365 days a year.

What if I want to be identified with my report?

There is a section in the report for identifying yourself, if you wish. If you call the hot line, you may give that information to your interviewer.

Other Questions You May Have

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, randomized number called a “Report Key” 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 investigator. Your follow-up report will be held in the same confidence as your initial report and with the same level of anonymity.

What if I lose my Report Key or forget the Password I created?

To ensure that security and confidentiality are maintained, if you lose your report key or password, you will need to file a new report. Mention in the new report that it is related to a report or question you previously submitted.

What are the consequences to me if I make a report?

Graco will make no reprisal against anyone who reports a violation or suspected violation in good faith. No one you identify in your report will be able to access your report. If you are a Graco employee, your identity will not be shared with your manager. You should be aware that in some circumstances the investigator may need to talk to people you have identified. If you provided your name, it will not be mentioned to them. The investigator will not answer questions about how they found out about the suspected violation other than that a report was made. The investigator may need to ask you for clarification or further information in order to be able to conduct a thorough investigation.

Will I be told the outcome of the investigation?

Although they may not be able to go into great detail, in many instances the investigator may notify you of the action taken by Graco on your report.