EthicsPoint - Arca Continental

Reporting Security & Confidentiality

About EthicsPoint

What is the Transparency Mailbox?

The transparency mailbox is an essential part of Arca Continental's Reporting System, it is a tool that allows us to listen to our associates or related third parties and initiate an investigation process on the facts, that leads us to correct all misconducts or behaviors contrary to our policies, treating the information with total confidentiality. Currently, this tool is managed by a specialized and independent company, NAVEX, and its platform is called EthicsPoint.

What is EthicsPoint?

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

Why do we need a transparency mailbox?

Our associates 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. the transparency mailbox enables you to file a confidential, anonymous report via either the telephone or the Internet.

What types of situations should I report?

The Transparency Mailbox allows employees to report any violation of our stated Code of Ethics, policies or other concerns you may have.

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 some behavior that you believe violates our code of ethics or policies, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager 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.

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 a healthy and productive environment. And avoid the exponential harm that misconduct can bring to us, to others and to Arca Continental.

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 Arca Continental 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 the EthicsPoint secure server. NAVEX makes these reports available only to specific individuals within Arca Continental 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.

Will there be any type of retaliation for making a report?

Any form of retaliation against a person who, in good faith, has reported a breach of integrity is strictly prohibited. If anyone experiences any form of aggression as a result of their report, they must report it through any available channel, including the Transparency Mailbox.

The Transparency Mailbox guarantees the confidentiality of the person’s data or even their anonymity when submitting a concern through any means. Fear is often understandable, especially when the situation being reported is serious or close to the individual. However, the design of the Transparency Mailbox is precisely intended to provide assurance that there is nothing to fear and that no one will be forced to disclose any information they do not wish to provide.

Will I get notice of the resolution?

You will be informed through this tool about the status of the investigation and will be contacted if there is a need to clarify any information. The content of the investigation is confidential.

How long will my report take?

"NAVEX sends the information to the corresponding ethics committee after the concern has been filed; the investigation and resolution period should not exceed 30 consecutive days, extendable."

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 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 the Transparency Mailbox 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 toll-free 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.

Tips & Best Practices

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

Arca Continental promotes ethical behavior. 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 lapse in ethics can have on an otherwise healthy company. If you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it.

I am not sure if what I have observed or heard is a violation of Arca Continental’s policies, 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 Arca Continental 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 Transparency Mailbox again either by Internet or telephone and access the original report to add more detail or answer questions posed by a company representative. We strongly suggest that you return to the site in the time specified to answer questions. You and the ethics committee now have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

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