The Ethics Line is a simple, confidential way for employees world-wide to ask questions, raise concerns or report situations that may cause or contribute to problems in the workplace. Bausch + Lomb of Americas Incorporated provided the Ethics Line as a mean of communication in addition to many other local and corporate resources that are available. It consists of toll-free telephone lines that are available anytime - 24 hours a day, seven days a week in over 100 languages, and an online reporting service, subject to certain limitations of local law. It is operated by an independent firm, not Bausch + Lomb of Americas Incorporated, to ensure the highest degree of confidentiality possible.

No. You are not required to identify yourself when you use the Ethics Line. Keep in mind that the Ethics Line is confidential and providing your name and contact details will enable investigators to follow up with you if they need more information or have questions. All reports, anonymous or not, are taken seriously and no employee will be retaliated against for placing a call or making a report in good faith.

EthicsPoint is a comprehensive and confidential reporting tool to assist management and employees to work together to address fraud, abuse, and other misconduct in the workplace, all while cultivating a positive work environment.

• 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.
• An effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision-making.

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

The EthicsPoint system is designed for employees to report any violation of Bausch + Lomb of Americas Incorporated's Code of Business Conduct and Ethics, or other concern you may have.

When you observe some behavior that you believe violates our Code of Business Conduct and Ethics, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager, or other member of our management team. Management may be able to address your concern immediately. You can also talk to Human Resources, Corporate Compliance, the Law Department, Corporate Security, or Corporate Audit Services. 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 EthicsPoint. We would rather you report the issue, anonymously if desired, than keep the information to yourself.

We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment. Employee misconduct can threaten the livelihood of an entire company.

We certainly do. In fact, we need you to report. You know what is going on at Bausch + Lomb of Americas Incorporated - 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 Company culture and performance.

Reports are entered directly on the EthicsPoint secure server to prevent any possible breech 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.

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.

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 any PC outside our work environment (such as one located at an Internet café, at a friend’s house, etc.) through the EthicsPoint secure website.

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.

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…”

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.

Bausch + Lomb of Americas Incorporated chooses to promote ethical behavior because we recognize that it is critical to the long term success and health of our Company. 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.

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.

It's not necessary to collect more information - and, in fact, it could compromise the Company’s investigation. Simply report what you know to your manager, Human Resources, Corporate Compliance, the Law Department, Corporate Security, Corporate Audit Services, or the Ethics Line. It is always helpful to have as much information as possible (names, dates, etc.), but any information could help to prevent a serious issue. Remember, all information provided to the Ethics Line is carefully reviewed. No action is taken unless independent, supporting evidence is gathered.

It's important to bring the issue to someone's attention, and your report, if made in good faith, cannot and will not be used against you. You should report any misconduct you know about or suspect, even if you're not certain of all the facts.

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.

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 be resolved, no matter how complex.

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

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 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.

No. The Ethics Line calls are received by EthicsPoint, an independent third party, and are never traced or recorded.

All calls are answered by an EthicsPoint Communications Specialist. The Communication Specialist will ask you questions to gather information, such as the reason why you are calling and the details of the particular issue. The specialist will take notes as you describe your question or concern. At the end of your conversation, you will be given a unique case number and asked to create a password. You will need this information to call back or go online to get the Company’s response. You can also use your case number to call back and add additional information if you forgot something or new information becomes available.

After each call, the EthicsPoint Communications Specialist prepares a detailed report and sends it to the Vice President and Chief Compliance Officer for review. Reports made online are routed directly to the Vice President and Chief Compliance Officer. The Vice President and Chief Compliance Officer ensures the question or concern is handled appropriately and taken seriously. Based on Company policy and procedure, Bausch + Lomb of Americas Incorporated will determine what action is necessary to address the situation. The information is reported back to the Ethics Line so that you can call back to get the Company’s response. The Company may not always be able to share specific information regarding the action taken, but will always provide a response.