Business Conduct and Ethics Reporting

Frequently Asked Questions

About EthicsPoint

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What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool to assist management, employees and other company stakeholders to work together to address violations regarding ethics and compliance issues in the workplace, all while cultivating a positive work environment.

Why does MTS need a system like EthicsPoint?

  • 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.
  • Publicly traded companies are required by law to have a confidential, and an anonymous reporting vehicle to address questionable accounting and auditing matters.
  • An effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision-making.

Reporting – General

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What type of situations should I report?

EthicsPoint is a communications tool for providing an avenue for sharing information about potential ethics and compliance violations. We have defined a number of choices available to you to categorize your report. If you feel that the definitions do not describe the event, action or situation you are looking to report, select "Other".

Can I report using either the Internet or the telephone?

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

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

If you are an employee of MTS and you observe some behaviour that you believe violates MTS's Code of Business 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. 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 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. Corporate misconduct can threaten the livelihood 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 offering positive input can minimize the potential negative impact on the company and our people. Also by reporting, you may help identify issues that can improve corporate culture and performance.

Where do these reports go? Who can access them?

Reports are entered directly onto the EthicsPoint secure server to prevent any possible breach in security. EthicsPoint makes these reports available only to specific individuals within MTS who are charged with evaluating the report based on the type of violation. Report recipients who are named in a report will not receive a copy of the report. 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?

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.

Reporting Security & Confidentiality

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It is my understanding that any report I send from a company computer generates a server log that shows every web-site that my PC connects with, and won't this log identify me as a report originator?

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 a PC outside MTS's 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 EthicsPoint's data shows that fewer than 12% of reports are generated during business hours.

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 anonymity. 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 desk next to Jan Smith…" or "In my 33 years…"

Is the telephone toll-free communication 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 for identifying yourself, if you wish.

What should I do if I lose my report key or password?

Because of the secured access necessary for maintaining the reports, if you lose your report key or password, you will be required to file a new report. You can mention in the new report that this matter relates to prior report and provide information that may allow the company to link the two reports.

Tips & Best Practices

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I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?

Our company chooses to promote ethical behaviour. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. So 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 company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

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 behaviour go unchecked because you weren't sure.

What if a situation I have observed is an emergency? What should I do?

EthicsPoint is not a 911 emergency service. You should report urgent emergency situations to your local police detachment or other emergency services immediately.

How long will it take for my report to be addressed?

MTS makes every effort to address all reports without delay. You are also encouraged to follow up on your report as many times as necessary using the EthicsPoint toll-free line or website.

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 are designed so 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 at the EthicsPoint Web site or through the EthicsPoint Call Center, you receive 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 a company representative and add further information that will help resolve open issues. We strongly suggest that you return to the site 5-6 business days after completing your report 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.

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.

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 or are uncomfortable using a computer, you can call the EthicsPoint toll-free number 1-855-236-6970 which is available 24 hours a day, 365 days a year.

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Note: EthicsPoint is NOT a 911 or Emergency Service: Do not use this site to report events presenting an immediate threat to life or property. Reports submitted through this service may not receive an immediate response. If you require emergency assistance, please contact your local authorities.

Paul Beauregard, Chief Corporate and Strategy Officer "As a corporate citizen, it is our responsibility to operate in an ethical manner. Business Conduct and Ethics Reporting provides a venue for MTS stakeholders to safely and confidentially communicate any questions or concerns in that regard, and to do so anonymously."
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