EthicsPoint - DENTSPLY SIRONA Inc.

Reporting Security & Confidentiality

About EthicsPoint

What is EthicsPoint?

EthicsPoint (the Dentsply Sirona Ethics Hotline) is a comprehensive and confidential reporting tool (developed by our vendor, 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?

At Dentsply Sirona, our core values include being accountable to each other, to be respectful to each other, and to be trustworthy so that our customers, partners, and fellow colleagues can rely on us. By creating open channels of communication, we promote a positive work environment for our most important asset — our people.
By law, we are required to maintain an operating reporting channel allowing employees and external third parties to raise their concerns. 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, where permissible under local law.

What type of situations should I report?

In general, employees should report any known or suspected violation of law or regulation, our Code of Ethics & Business Conduct (“Code”), or other company policies and procedures.

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

When you observe behavior that you believe violates our Code, we expect and encourage you to report it. You should feel free and empowered to bring any concerns forward to your direct manager, Human Resources partner, Global Ethics & Compliance team, or other member of our management team. That said, we recognize, that there may be circumstances when you are not comfortable reporting a concern in this manner. That is why we have partnered with NAVEX to establish the EthicsPoint hotline, where you may be able to submit a report anonymously.

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

Workplace misconduct can have significant stakes, including threatening the very existence of an entire company. But any violation of company policy poses risk to the positive work environment that we all endeavor to create on a daily basis.

When you hear or see actions, conduct or behavior that you suspect does not align with our Code or our values, you have an obligation to report it. We all have the right to work in a positive environment and with that right comes the responsibility of acting ethically and being a gatekeeper for our corporate culture. By working together, we can maintain a healthy and productive environment.

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 EthicsPoint’s secure server. NAVEX makes these reports available only to specific individuals within the company who are charged with evaluating the initial report and then determining how best to respond, based on the type of violation and location of the incident. All concerns are reviewed and taken seriously.

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.

Reporting Security & Confidentiality

It is my understanding that any report I send from a company computer generates a server log that shows every website that my computer 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 computer to EthicsPoint is available.

If you feel uncomfortable making a report on your work computer, you have the option of using another computer outside of our work environment (such as a personal computer at home, an Internet café computer or a friend’s computer) through EthicsPoint’s secure website.

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?

If you wish to remain anonymous, and are in a jurisdiction where anonymous reporting is permitted by law, your anonymity will be protected. Only information you choose to provide to EthicsPoint will be shared with the company. However, as a reporting party, you must also take care that the factual information you share is specific enough to relay your concern without being so specific that it reveals your identity by accident. For example, you may wish to avoid saying “From my cube next to Jan Smith…” or “In my 33 years working in the X location…”.

Is the toll-free hotline confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and a trained Operator will enter your responses into the EthicsPoint system. These reports have the same security and confidentiality measures applied to them.

What if I want to be identified with my report?

We encourage you to identify yourself when you make a report, if you are comfortable doing so. Dentsply Sirona has a strong non-retaliation policy, which means that no one can take any negative actions towards you simply because you made a good-faith report or shared a concern.

Tips & 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, hurts the company and its employees, including you. It also can have negative effects on our customers and patients. That is why it is so important for you to report any known or suspected incidents of misconduct or ethical violations, even if you do not perceive a direct impact on you.

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?

Please speak up and file a report. Our partner, NAVEX, can help you prepare and file your report in EthicsPoint so it can be properly understood. And report recipients are trained to evaluate whether reports raise violations of company policies or other unethical conduct. It is always safer to 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?

When you file a report through EthicsPoint, you are prompted to provide the names of anyone who is involved in the misconduct and that you do not want to have access to your report. As long as you identify the specific parties during the intake process, EthicsPoint ensures 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 through EthicsPoint, regardless of whether you go online or call the hotline, you receive a unique, randomized number called a “Report Key” and are asked to choose a password. You can return to the EthicsPoint system online or by telephone at any time and access the original report to add more detail or answer questions posed by a report recipient. We strongly suggest that you return to the site within two business days to answer company questions.

Are these follow-ups on reports as secure as the first one?

Yes. All communications through EthicsPoint are held in the same strict confidence as the initial report. If you chose to report anonymously, your initial report and all follow up submissions will remain anonymous.

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

To maintain the security and confidentiality of all reporters, you will not be able to access your original report and will need to file a new report. When you file a new report, you should mention that it is related to a prior report or question you previously submitted.

Can I still file a report if I don’t have access to the Internet?

Yes. 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.

You can also file an EthicsPoint report from any computer that can access the Internet.