About EthicsPoint

Reporting – General

Reporting Security & Confidentiality

Tips & Best Practices

About EthicsPoint

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX that enables management and employees to work together to address fraud, abuse, and other misconduct in the workplace while cultivating a positive work environment.

Why do we need a system like EthicsPoint?

• Our employees are our most important asset. By creating open channels of communication, we promote a positive work environment and maximize productivity.
• An effective reporting system augments our other efforts to foster a culture of integrity and ethical decision-making.

Reporting – General

May I report using either the Internet or the telephone?

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

What types of situations should I report?

The EthicsPoint system allows you to report any violation of Habitat’s Code of Conduct or other concerns you may have. Typically, complaints filed to HEAL should be those concerns that fall under the Immediately Reportable Criteria, which are set out in the chart below. Because HFHI leadership monitors the incidence of serious allegations as part of its continuous improvement efforts, managers of Habitat organizations are expected to report such concerns to HEAL even if the concerns are already being addressed.

For most other concerns, employees are encouraged first to address them to their direct supervisor, their HR department, or other leader in their Habitat organization. Whether your grievance or concern is more suitable for the HR channel of reporting or the Habitat Ethics and Accountability Line / GRC-Investigation channel of reporting depends on multiple factors, including the subject matter of your concern and whether you wish to remain anonymous (an option available only when using the Habitat Ethics and Accountability Line).

If you are unsure where you should report your concern, please choose the approach with which you are most comfortable. HFHI personnel monitoring both intake methods will review your concern, consult with their HR and GRC-Investigations colleagues and route your issue to the right team.

Concerns involving the issues below are likely to be routed to HR, which will partner with relevant management to resolve the issue. Even if you report the issue to the Habitat Ethics and Accountability Line, it is likely to be shared with HR for tracking and management by HR.

• Unfair treatment or conduct by management
• Workplace substance abuse
• Nepotism or favoritism
• Unfair termination or other disciplining (not alleging discrimination of the type defined below)
• Disrespectful language
• Poor team management
• Allegations of mismanagement
• Poor customer service
• Unwanted solicitation by/among Habitat team members
• General workplace health and safety concerns

Concerns involving these "Immediately Reportable Criteria" are likely to be routed to the Habitat Ethics and Accountability Line for potential handling by GRC-Investigations. Even if you report the issue to HR, it is likely to be shared with GRC-Investigations for its assessment of proper next steps and for potential reporting (anonymized and aggregated) by GRC to HFHI's audit committee of the International Board of Directors (IBOD).

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

When you observe some behavior that you believe violates our code of conduct, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager or other members 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.

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

We all have the right to work in a safe and effective 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. Misconduct can threaten the very existence of an entire organization.

Does management really want me to report?

We certainly do. In fact, we need you to report to help maintain a safe and effective work environment. You know what is going on in our organization - 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 organization and our people. Also, offering positive input may help identify issues that can improve organizational culture and performance.

Additionally, there is an obligation on managers of Habitat organizations to report incidents that fall within the Immediately Reportable Criteria.

“You have a voice within Habitat for Humanity and it is your responsibility to hold us all accountable.” – Jonathan Reckford, CEO.

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPoint secure server, which is independent of any HFHI platform. NAVEX makes these reports available only to specific individuals within HFHI 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?

No. EthicsPoint is a positive aspect of our overall philosophy that allows us to ensure 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.

How long will it be for the incident to be addressed?

It depends. Based on the severity and urgency of the situation, different cases have different priorities and complexity. However, the Investigations team at HFHI strive to address all issues as soon as possible. Once the issue has been addressed, a notification will be sent in the system to show the case is closed.

Every complaint that is filed to HEAL is responded to. Please note that results of addressing your complaints and/or investigation are not shared with complainants or listed out in the HEAL system due to confidentiality reasons. When a case is finished/closed there will be a message sent within the system alerting the complainant the case has been closed and GRC is working with management on any related follow-up or improvements as needed. There is no expectation that detailed results will be shared with complainants.

Reporting Security & Confidentiality

It is my understanding that any report I send from an organization computer generates a server log that shows every website that my PC connects with. Won’t this log identify me as the 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.

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 or at a friend’s house) through the EthicsPoint secure website. Many people choose this option, as NAVEX 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.

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 protects 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 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 to identify yourself, if you wish. It is perfectly fine to remain anonymous, but it is more effective for contact details to be shared so the investigation team can ask clarifying questions to make sure they understand the complaint themselves and gather additional information. You can set up an email address with no identifying information to allow the investigators to contact you (e.g., anonymous1234@gmail.com)

Tips & Best Practices

I am aware of some individuals acting unethically, but it doesn't affect me. Why should I bother reporting it?

Our organization promotes ethical behavior. All unethical conduct, at any level, ultimately hurts the organization and all employees, including you. You only have to consider what happened in recent corporate scandals to see the disastrous effects that a lapse in ethics can have on an otherwise healthy organization. If you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it.

What should I include in my complaint?

• When including names in the complaint details, please enter full names and titles of the people you mention in the report if you know them as the Investigator will generally not know who you are referring to, especially if it is a more common name as that will add confusion and delay into looking at your concerns.
• If you are within the United States, please be specific to the geographic location of the incident, the name of the U.S. Affiliate/county, and/or event(s) you are referring to. This will help the investigators direct the concern to the correct place.
• There is not much, if anything, the Investigations team can do when receiving vague complaints/ allegations that include no dates, times/time period, individuals involved, etc. For example, instead of saying “John Doe is corrupt and doing bad things”, provide details of the events such as “on July 10, 2022, John Doe accepted cash kickbacks at 123 Bank Street in New York.”
• Avoid using threatening language in your complaint details. The Investigators are doing their best to try and look into and resolve your concerns.
• Do not purposefully file false and factually inaccurate complaints to try and get back at someone or to mislead the investigators. It is against Habitat for Humanity Ethics Covenant to mislead the investigators.
• Please do not intentionally file duplicate cases because you feel you have not heard back from us. This will only slow down the process of reviewing and addressing your concerns.

I am not sure if what I have observed or heard is a violation of organization 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.

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 ensure 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 organization 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 an organization representative. We strongly suggest that you return to the site in the time specified to answer organization questions. You and the organization now have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

If you state you have supporting documents, be sure to attach them with your complaint. If a complainant has supporting documentation, please attach it directly into the HEAL system when filing your complaint. If you are unable to do so, you can send it to heal@habitat.org and let us know which complaint this in reference to.

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.

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

To ensure that security and confidentiality is 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 you previously submitted.

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 hotline, which is available 24 hours a day, 365 days a year.