Ethics
Helpline

Questions & Answers

"FCA Ethics Helpline" - Commonly Asked Questions

What is the "FCA Ethics Helpline"?

The "FCA Ethics Helpline" is a comprehensive and confidential reporting tool to assist FCA workforce members to report concerns or seek guidance regarding the FCA Principles outlined in the "Code of Conduct" or our other corporate policies (including alleged fraud, abuse, and other misconduct in the workplace) or applicable laws.

Why do we need an "FCA Ethics Helpline"?

Our workforce is our most important asset. By creating open channels of communication, FCA can promote a positive work environment and maximize productivity. An Ethics Helpline allows for an effective reporting system which will aid in our efforts to foster a culture of integrity and ethical decision-making.

What is NAVEX Global?

NAVEX Global is an independent third party service provider that has been retained by FCA to administer the "FCA Ethics Helpline" and case management application.

What is the difference between NAVEX Global, Inc. and EthicsPoint?

EthicsPoint is the name of the helpline services and case management application owned and operated by NAVEX Global, Inc.

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Reporting - General

What type of situations should I report?

The "Ethics Helpline," is designed for employees to ask questions and report any concerns pertaining to the Principles outlined in the FCA "Code of Conduct", our other corporate policies or applicable laws.

The Ethics Helpline is a resource for the FCA workforce. You are encouraged at any time to ask questions related to the Code of Conduct, Principles, Practices, or Procedures.

If I see a violation, can I report it to my manager, human resources or legal and compliance area to address?

When you observe any behavior you believe may violate the Principles contained in the "Code of Conduct," other corporate policies, or applicable law we encourage you to report the matter as soon as known. The concern should be reported through the “Ethics Helpline” (web or telephone). In case of system unavailability you can bring any questions or concerns forward to your managers, Human Resources Department, Internal Audit and Compliance Department, Legal Department, or as otherwise provided under local reporting procedures.

May a report be filed either via the Internet or the telephone?

Yes, the process allows for both web-intake and telephony services.

Why is it important to report a concern?

We all have the right to work in a positive environment. With this right comes the responsibility of acting in an ethical manner and letting the appropriate people know if you believe someone is not acting appropriately. By working together, we can maintain a healthy and productive work environment. Violations of the Code of Conduct, other corporate policies or the Law can threaten the assets, goodwill and reputation of an entire company. Reporting a concern allows those responsible for conducting due diligence to ensure the matter is properly addressed.

Does FCA really want me to report?

Absolutely! We encourage you to report concerns and ask questions. Workforce members know what is going on in our company and may have initial knowledge of an activity that could be cause for concern. Your reporting can minimize the potential negative impact on the company and our workforce.

Where do these concerns go?

Concerns are entered directly into NAVEX Global's secure server to prevent any possible breach in security.

Who can access the reported concern?

Reported concerns are made available by NAVEX Global only to specific individuals within FCA who are entrusted with evaluating the reports, based on the type of reported concern and location of the incident. Each of these report recipients has had training in keeping these reports confidential to the fullest extent practicable under the circumstances.

Is the system just an example of someone watching over me?

The NAVEX Global system is a tool utilized by FCA to aid us in maintaining a safe, secure, and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, and communicate any potential concern. Effective communication is critical in today's workplace and this is a great tool to enhance that communication.

FCA has carefully chosen this reporting tool to meet our compliance needs while maintaining a positive reporting environment.

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Reporting Security & Confidentiality

It is my understanding that any concern I send from a company computer generates a server log that shows every website my PC connects with; won't this log identify me as a report originator?

NAVEX Global does not generate or maintain any internal connection logs with IP addresses; no information linking your PC to NAVEX Global is available when you access the "Ethics Helpline." In fact, NAVEX Global 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 of the work environment through the NAVEX Global secure website. Many people choose this option.

Can I file a concern from home and still remain anonymous?

No matter where a report is generated it will remain protected, confidential and anonymous. An Internet portal never identifies a reporter by screen name and the NAVEX Global system strips away identifying information, such as an IP address, so that anonymity is maintained. Plus, NAVEX Global is contractually committed not to pursue a reporter's identity.

Please be aware that anonymous reporting may not be permitted in some countries.

I am concerned the information I provide NAVEX Global will ultimately reveal my identity. How can you assure me that will not happen?

The NAVEX Global system is designed to protect your anonymity. In fact, NAVEX is contractually committed not to pursue a reporter's identity. To further ensure your anonymity, you - as a reporting party – should not reveal any identifying details as part of your report.

Please be aware that anonymous reporting may not be permitted in some countries.

Is the telephone toll-free helpline confidential and anonymous?

Yes. A reporter will be asked to provide the same information that would be provided in an Internet-based report. The representative will type your responses directly into NAVEX Global's secure environment. Telephone helpline-based reports have the same security and confidentiality measures applied to them during delivery as Internet-based reports.

Please be aware that anonymous reporting may not be permitted in some countries.

Does it help if I identify myself?

Investigating a report is usually faster and more efficient when the FCA Team is able to follow up on the issue directly with the person reporting the matter. If you have identified yourself, reasonable efforts will be made to respect your confidentiality. Your identity will not be disclosed unless necessary for carrying out a proper investigation, required in the course of legal proceedings, or as required by local laws or local company mandates. FCA will not tolerate any form of retaliation for reporting a concern in good-faith.

How can I monitor the progress of my concern if I choose to remain anonymous?

Once you have finished reporting your concern, you will be provided with a report key and asked to create a password. With these two pieces of identification, you will be able to follow up on a report, either by visiting the "Ethics Helpline" portal or contacting the telephone helpline. You may need to wait a few days after your submission before you can monitor progress and check whether you are being asked for any additional information. To allow for protection of the matter and any parties involved, details of the case cannot be provided.

What if I lose my report key or password?

In order to maintain the highest level of confidentiality, you will be asked to file a new concern if you lose either your report key or your password. You should mention that your new report relates to one filed earlier.

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Tips & Best Practices

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

FCA chooses to promote ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. Disastrous effects can occur in an otherwise seemingly harmless lapse of poor decision making. If you are made aware of any incident of alleged misconduct or ethical violation, consider it your responsibility to report the incident, no matter how trivial it may initially appear.

I am not sure if what I have observed or heard is a violation of FCA’s Code of Conduct, Principles, company policy, applicable law or involves unethical conduct, but it just does not look right to me. What should I do?

File a concern. NAVEX Global can help you prepare and file your concern so it can be properly understood. FCA would rather you report a situation that turns out to be harmless than let a possible unethical or illegal behavior go unchecked because of uncertainty.

What if my boss or other managers are involved in a violation? Will they get the report?

The NAVEX Global system and report distribution protocols are designed so implicated parties are not notified about or granted access to reports in which they have been named, unless required by local laws.

What if I remember something important about the incident after I file the concern?

When you file a concern via the "Ethics Helpline," either using the portal or through NAVEX Global's telephony, you receive a unique report key and are asked to select a password. With the report key and your password, you can return to the NAVEX Global system again, either by Internet or telephone, and access the original report. At that point, you can add more details.

What if you have questions for me concerning my report?

NAVEX Global provides functionality that enables FCA representatives to post questions for you, even if you report anonymously. When you receive your report key, you will be provided with the amount of time we expect for the report to be processed. When that time has passed, we strongly suggest you check to see if any questions have been posted. Providing the opportunity for such dialogue aids in investigating matters.

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

All NAVEX Global correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity, if you so choose, to the extent permitted by local law and local company mandate.

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

You can file a report via the "Ethics Helpline" from any computer that can access the Internet. If you do not have access to, or are uncomfortable using a computer, you can call the Ethics Helpline, which is available 24 hours a day, 365 days a year. International dialing options are available, by country, on the website.

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