Frequently Asked Questions About: WORLDPAY ETHICS and INTEGRITY LINE THROUGH ETHICSPOINT
Reporting – General
Reporting Security and Confidentiality
Tips and Best Practices
Frequently Asked Questions About: WORLDPAY ETHICS and INTEGRITY LINE THROUGH ETHICSPOINT
Ethical business practices and conduct are a top priority at Worldpay as reflected in our Code of Business Conduct and Ethics (“Code”). Ethical behavior and company values impact our entire business, including our reputation with clients and shareholders, our dealings with suppliers, our communications with regulatory agencies and our interactions with colleagues in the workplace. Our values are how we work together to deliver our purpose each and every day to Think like a customer, Act like an owner, and Win as a team..
At Worldpay, we focus on integrity and we Speak Up when we have concerns. Worldpay has zero tolerance for retaliation.
WHAT IS THE WORLDPAY ETHICS and INTEGRITY LINE?
EthicsPoint is a comprehensive and confidential reporting tool created by our third-party vendor, NAVEX, to assist anyone with a working relationship with Worldpay to Speak Up and report wrongdoing. Through EthicsPoint, you can file a confidential report and have the option to remain anonymous.
Why do we need a system like EthicsPoint?
By creating open channels of communication, such as the Worldpay Ethics and Integrity Line and our Worldpay Ethics Office (WorldpayEthicsOffice@worldpay.com) we promote a positive work environment to Act like an owner and maximize productivity to Win as a team. An effective reporting system supports our efforts to foster a culture of integrity and ethical decision-making. It also allows the company to learn of concerns or suspicions of unethical conduct and take actions to address these behaviors.
Reporting – General
Who can report?
Anyone with a working relationship with Worldpay, whether as an employee, contractor, client, supplier or other third parties can raise concerns or suspected misconduct relating to Worldpay or its employees via the Worldpay Ethics and Integrity Line or directly to our Ethics Office (WorldpayEthicsOffice@worldpay.com).
May I report using either the Internet or the telephone?
Yes, both telephone and internet reporting channels are available. You may also be able to request an in-person meeting via the Worldpay Ethics and Integrity Line.
What type of situations should I report?
Examples of matters that should be reported to the Worldpay Ethics and Integrity Line:
- Violation of the Code or any Worldpay policy or standard.
- Violation of any law, regulation, or rule, including theft, embezzlement or other criminal conduct.
- Conflicts of interest, insider trading or unfair dealings.
- Falsification of any time reporting or company records, fraud, financial or accounting misconduct or questionable auditing practices.
- Bribery and/or corruption that includes but is not limited to Foreign Corrupt Practices Act (FCPA) and U.K. Bribery Act violations.
- Retaliatory behavior.
- Any other serious misconduct by managers, colleagues, contractors, suppliers or vendors.
If I see a violation, shouldn't I just report it to my manager, security, or the People and Culture Team and let them deal with it?
When you observe unethical behavior, we want you to Speak Up and report it.
You can raise concerns directly with your direct manager, or other member of the Worldpay management team, People and Culture or the Worldpay Ethics Office (WorldpayEthicsOffice@worldpay.com).
We recognize, however, that there may be circumstances when you may be more comfortable reporting your concerns via the Worldpay Ethics and Integrity Line.
Why should I report what I know? What’s in it for me?
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 an ethical, productive, and compliant work environment. Corporate misconduct can threaten the very existence of an entire company.
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 your colleagues. Offering positive input may help identify issues that can improve corporate culture and performance.
Where do these reports go? Who can access them?
Worldpay Ethics and Integrity Line reports are entered directly on the EthicsPoint secure server located in the United States.
Our Ethics and Integrity Line and website is operated by an independent external organization, NAVEX (www.navex.com).
Once you report a matter to our Ethics and Integrity Line, it is routed to the Chief Ethics Officer and one member of the Ethics team for review. The matter is then assigned to a lead investigator. Investigations are conducted in a confidential manner; information about an investigation will only be shared with or communicated by the investigator to those who have a legitimate need to know about the investigation.
Isn’t this system just an example of someone watching over me?
No. EthicsPoint is a positive aspect of our corporate culture 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.
Can I report in another language?
Yes, most languages are supported on the website. All calls are answered in English; however, you are able to continue the call in another language.
Reporting Security and Confidentiality
It is my understanding that any report I send from a company computer generates a server log that shows every website 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. If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside of the 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 NAVEX’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 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 is designed to protect your identity should you choose to make an anonymous report. However, if you wish to remain anonymous, you - as a reporting party – also 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 Ethics and Integrity Line confidential and anonymous too?
Yes. You will be asked to provide the same information that you would provide in an internet-based report when reporting via telephone. Regardless of method use to make a report, it is secure and confidential.
Will my call be recorded?
No, but a note will be taken to create a report.
What if I want to be identified with my report?
There is a section in the report for identifying yourself, if you choose to do so.
Tips and Best Practices
I am aware of some individuals acting unethically, but it doesn’t affect me. Why should I bother reporting it?
Our company promotes ethical behavior. All unethical conduct, at any level, ultimately hurts the company and its colleagues, 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. Therefore, if you know of any incidents of misconduct or ethical violations, it is your duty 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. We would 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 process are designed so that named parties are not notified or granted access to reports.
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, you receive a unique, randomized number called a “Report Key” and are asked to choose a password. You can return to the EthicsPoint system either by internet or telephone and access the original report to add more detail or answer questions posed by a company representative. We strongly encourage you to return to the site in the time requested to answer company questions. Any dialogue with the company will remain anonymous unless you choose to disclose your identity.
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, including the ability to remain anonymous.
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.
Can I still file a report if I don’t have access to the internet?
You can file a report from any computer that can access the internet. If you don’t wish to file a report using a computer, you can call the toll-free Ethics and Integrity Line, which is available 24 hours a day, 365 days a year.
Do What Is Right and Speak Up!
We want to hear from you. Remember, an issue cannot be addressed unless it is brought to someone’s attention. If you see or suspect a violation of our Code, company policies or the law, it is your duty to Speak Up and report it to management, People and Culture or the Ethics and Integrity Line. The Ethics and Integrity Line is available to anyone having a working relationship with the company.
In addition, you can contact the Worldpay Ethics Office at WorldpayEthicsOffice@worldpay.com with your concerns. Worldpay has zero tolerance for retaliation.