Frequently Asked Questions

  • Who may report a speak up concern?

    • Any employee, and where permitted by law, any contractor, supplier, distributor or customer, may report a concern relating to potential wrongdoing involving Brambles.

  • What is EthicsPoint?

    • EthicsPoint is a comprehensive and confidential telephonic and web-based reporting tool operated by NAVEX, an independent, third-party. EthicsPoint may be used by any Brambles employee to report potential wrongdoing in the workplace.

  • Why has Brambles contracted with NAVEX for the use of EthicsPoint?

    • We believe that our employees are our most important asset. By creating open channels of communication, we can promote a positive work environment where employees feel safe knowing they can raise good faith concerns about the workplace.

    We believe that EthicsPoint helps promote this environment. EthicsPoint is operated by NAVEX, an independent, third-party that provides secure, confidential telephone and web-based systems for use by those who wish to report concerns of potential wrongdoing in the workplace. Brambles is one of many companies that contracts with NAVEX for this service, believing that its employees will feel more comfortable and secure reporting a concern if they know they will be reporting to a professional third-party.

  • What is NAVEX’s role?

    • NAVEX’s primary responsibilities include:

    • Providing EthicsPoint—a confidential telephone and web-based option for employees and other authorized reporters to speak up about potential wrongdoing in the workplace;
    • Protecting the identity of employees and other authorized reporters who wish to remain anonymous;
    • Providing translation services for those who wish to speak up in a language other than English;
    • Transmitting information about the potential wrongdoing to the Brambles Legal Team so that, where appropriate, the company can conduct a confidential investigation; and
    • Allowing Brambles to communicate with an anonymous reporter by serving as an intermediary. As an intermediary, NAVEX relays follow-up questions and answers as well as the status of any investigation and case resolution to the reporter through EthicsPoint.

    NAVEX does not investigate speak up reports or otherwise take action to resolve them. It simply relays the concern, securely, confidentially and, where requested, anonymously to the Brambles Legal Team.

  • What if I need to report an emergency?

    • Concerns about an immediate threat of physical harm to you or to others or damage to property as a result of a natural disaster or other event which may require evacuation should not be reported through EthicsPoint. If you need emergency assistance, please contact your local emergency services.

  • Should I speak up about my concern through EthicsPoint or to my manager or human resources representative?

    • You should consider whether you are comfortable raising your concern directly, such as to your manager, your manager’s manager, or to someone else in your department. Individuals within the company have indicated that, while sometimes challenging, directly addressing issues or concerns with those involved can be very effective. You may also report any concern you have to your human resources representative or a member of the Legal Team. If you are uncomfortable reporting your concern, if you do not know who to contact, if you believe your concern has not been addressed satisfactorily, or if you wish to remain anonymous, you may file a report with EthicsPoint.

  • What type of situations should I report?

    • The EthicsPoint system is designed for employees to speak up about any potential violation listed in our Speaking Up Policy, or other concerns you may have. Generally, and subject to any limitations imposed by local law, the Speaking Up Policy covers employees who wish to disclose actual or planned activities covering any one or more of the following: (i) criminal activity; (ii) the failure to comply with any legal or regulatory requirements; (iii) dangers to health and safety; (iv) damage to the environment resulting from the release of toxic substances or environmental waste or violation of applicable environmental law or regulation; (v) questionable accounting, internal accounting or auditing mismanagement; (vi) bribery or corruption; (vii) the unauthorized disclosure of trade secrets or proprietary or confidential information; (viii) any other breach of Brambles’ Code of Conduct or any conduct likely to damage Brambles’ reputation; or (ix) the deliberate concealment of any of the above.
    You should be aware that some jurisdictions limit the types of concerns that can be raised. As a result, for further clarification on when to speak up using EthicsPoint, please consult your local policy (if any) or speak to your local Legal Team representative.

  • May I speak up using either the Internet or the telephone?

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

  • Do I have to give my name if I speak up using EthicsPoint?

    • In those countries where anonymous reporting is allowed, you do not have to give your name to EthicsPoint when you speak up. Both the web-based platform and the telephonic hotline are totally confidential. However, Brambles strongly encourages you to disclose your identity. In many cases, it is difficult—if not impossible—to investigate anonymous claims. By providing your name, you facilitate the investigative process. If you ultimately choose to remain anonymous, your report will be referred to by an assigned report key number.

    In those countries where anonymous reporting is not allowed, you will have to disclose your identity. Again, we will respect confidentiality. This means that only those who need, or have a legal right, to know will be made aware of your identity and your complaint.

  • How does EthicsPoint maintain confidentiality?

    • EthicsPoint does not trace calls or use Caller Identification. Additionally, EthicsPoint does not generate or maintain internal connection logs containing Internet Protocol (IP) addresses, so no information linking your computer to EthicsPoint would be available if you choose to speak up online. Reports from your computer would come through a secure Internet Portal which does not trace or show user names.

  • How can I monitor the progress of my speak up concern?

    • At the end of your telephone call or web-based report, EthicsPoint will provide you with a report key and ask you to create a password. You will be asked to telephone Brambles’ Speak Up Hotline, operated by EthicsPoint, or visit the EthicsPoint website, 7 to 10 days after you make your initial report. At that time, you can monitor progress on your speak up report and learn whether any additional information is needed from you to address your concern.

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

    • Because of the high level of confidentiality, if you lose your report key or password, you will be required to file a new speak up report. You should mention in your new speak up report that this matter relates to another report you previously made.

  • Where do these reports go? Who can access them?

    • Reports are entered directly on the EthicsPoint secure server to prevent any possible breach in security. EthicsPoint makes these reports available only to specific individuals within the company 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.

  • Should I worry about retaliation?

    • Brambles strictly forbids retaliation or retribution against any person who raises a genuine concern. Speak up complaints made in good faith will not expose you to any discipline, regardless of whether the underlying facts prove to be true or require corrective action. If you believe you have faced retaliation or retribution of any kind, please report it so that Brambles can investigate.

  • Does Brambles really want me to speak up?

    • We certainly do. In fact, we need you to speak up. 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.