EthicsPoint is a comprehensive and confidential reporting tool managed by NAVEX, a premier ethics and compliance advisor, through which we are implementing our Code of Business Conduct Hotline. The purpose is to assist management and personnel to work together to address potential ethics issues, misconduct and other violations of the Baker McKenzie Code of Business Conduct, while cultivating a positive work environment. The EthicsPoint solution comprises a telephone reporting system and an internet/web portal reporting system. Any reference to the Hotline refers to both systems.
The Baker McKenzie Code of Business Conduct was introduced in January 2016 for the Firm globally, with application to lawyers and non-lawyers alike. The Code is many things:
Yes. With the Hotline, you report a suspected violation of the Code of Business Conduct or submit questions via either telephone or the Internet / web portal where permitted by local law to do so. The Hotline is a reporting option in addition to those options already contained in the Code of Business Conduct.
Yes, however, the ability to make anonymous reports may be subject to local legal and regulatory requirements (for example in some jurisdictions there are limits on the types of issues that may be reported anonymously). Generally, you are encouraged to provide your details rather than report anonymously, because if you choose to remain anonymous our ability to investigate the matter may be impaired and we may not be able to fully address all of your concerns.
The Hotline is designed for personnel to report any suspected violation of our Code of Business Conduct, professional responsibilities or the law. In some countries, there are local regulatory and legal restrictions that limit the categories of reports that can be submitted via a Hotline service. These restrictions have been incorporated into the Code of Business Conduct Hotline where applicable. To be clear, while these restrictions may apply to reports/concerns submitted via the Hotline, personnel can report any suspected violation of the Code of Business Conduct by any person to the Firm's Office of the General Counsel via the Global General Counsel or Director of Professional Responsibility, if the reporter is not comfortable submitting a report or concern to her or his immediate supervisor, human resources or a member of local management. The restrictions in some countries on reporting under the Hotline generally do not apply to reports to the Office of the General Counsel.
Personnel should feel free to report any suspected violations of the Code of Business Conduct, professional responsibilities or the law via the Hotline. Examples could include concerns about corruption, bribery, harassment, discrimination, conflicts of interest, and insider trading. Conversely, by way of example, general dissatisfaction with an individual's compensation, performance review, general personnel issues and related matters are often more effectively and appropriately dealt with at the local human resources level. Absent conduct that could involve a Code of Business Conduct violation, these issues should be handled locally rather than via the Hotline.
When you observe conduct or behavior that you believe violates our Code of Business Conduct, we expect you to report it, so that we can look into it. Ideally, you should first bring any concerns to the attention of your immediate supervisor, human resources or a member of local management. The Firm is committed to ensuring that you are comfortable making reports of any suspected violations of the Code of Business Conduct. If you are not comfortable reporting the issue to any of the individuals listed above, the Hotline is available to provide a further method to report whether by telephone or by a secure Internet page / web portal set up for the purpose of submitting such reports. If you would prefer, you can report directly to the Firm's Office of the General Counsel, via the Global General Counsel or Director of Professional Responsibility.
We all want to work in a professional and ethical environment. With that comes the responsibility of not only acting in an ethical manner but also letting the appropriate people know if you are concerned someone is not acting likewise. Corporate misconduct can threaten the well-being of an entire organization. We want people to share any potential breaches of the Code of Business Conduct or law so we can deal with them appropriately.
We do. In fact, we need you to report suspected violations in order to ensure that the Code of Business Conduct is being observed, applied and abided by. You see and hear what is going on in your part of the Firm - both good and, sometimes, bad. Your reporting can help minimize the potential negative impact on the Firm, our people and others. Also, offering suggestions and input may help identify issues that can improve our culture and performance.
Hotline reports are entered directly on the EthicsPoint secure server to prevent possible breaches in confidentiality. When a report is submitted via the telephone Hotline, details of it will by transcribed onto the EthicsPoint secure server. When the person making the report does so via the Internet / web portal he or she will insert details onto the secure server. In both cases, only appointed individuals in the Office of the General Counsel will have access to the reports. Once a report is submitted, individuals in the Office of the General Counsel will access and review it and will assess how to deal with the report, including whether to further investigate and, if so, whether the investigation should be referred to the local office / practice or industry group / business unit or conducted by the Office of the General Counsel or person(s) appointed by the Office of the General Counsel.
Sensitive personal data should only be included in a report where absolutely necessary to investigate the complaint.
If you make an anonymous report, from home or any Internet / web portal, it will remain secure and anonymous. An Internet page / web portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is maintained. As previously noted, the ability to submit anonymous reports is subject to local regulatory and legal restrictions in place in your country.
As discussed above, you are encouraged to provide your details rather than report anonymously, because if you choose to remain anonymous our ability to investigate the matter may be impaired and we may not be able to fully address all of your concerns.
If you make an anonymous report, the EthicsPoint system is designed to protect 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 cubicle next to Jan Smith…” or “In my 33 years in the [location] office…”.
Yes, unless you wish it not to be. You will be asked to provide the same information that you would provide in an Internet-based report and a NAVEX/EthicsPoint Interview Specialist will type your responses into the EthicsPoint website specifically designed for the Firm. These reports have the same security and confidentiality measures applied to them during delivery. Again, anonymous reports will be accepted if permitted by local legal and regulatory requirements.
There is a section in the EthicsPoint tool for identifying yourself, if you wish to do so.
We will always do our best to maintain confidentiality of those who make reports and the matters that are reported to us. However, we have a duty to investigate serious misconduct that is reported through the Hotline and in order to conduct a thorough investigation it is often not possible to maintain the confidentiality of information provided in a report.
As noted above, only selected persons in the Office of General Counsel will initially be notified of a Hotline report, and they will assess the next steps. These individuals will not be able to identify the person making the report unless the reporter has chosen to be identified. If you report a matter you will be provided with an unique username and password which you can log into to inquire about progress and to provide any additional information. Any additional queries from the Office of General Counsel will be directed to this anonymous account and you can continue to respond without revealing your identity. We require you to access this account and respond to any further questions or requests required to properly investigate the report as your assistance will likely be required to facilitate the investigation. Again the ability to submit anonymous reports will depend upon local legal and regulatory requirements. Even where anonymous reporting is permitted, we encourage you to identify yourself. If you choose to remain anonymous, our ability to investigate the matter may be impaired and we may not be able to fully address all of your concerns.
Yes. Our Global IT Security team has conducted a security check on the EthicsPoint system and is satisfied with the level of security provided. More than 10,000 organizations worldwide rely on EthicsPoint to help manage their compliance hotlines.
We have appropriate data processing agreements in place between your employing entity and the provider of the EthicsPoint system. The agreements oblige the provider to ensure that all personal data is adequately protected and legally processed.
Our Firm expects ethical behavior - it's a commitment not only to our people, but also to our clients and it is a central part of our Code of Business Conduct. All unethical conduct, at any level, ultimately stands to hurt the Firm and all of our people, including you. As a law firm we rely on compliance with ethical standards to protect the reputation of the Firm, which is critical to its continued success. So if you know of any incidents of misconduct, ethical violations, potential violations of the Code of Business Conduct, professional responsibilities or the law, consider it your duty to yourself and your colleagues to report it.
Ask a question through the Hotline. The EthicsPoint system allows you to seek guidance by asking questions before you lodge a report if you are uncertain. We'd rather you ask a question about conduct that turns out to be harmless, than let possible unethical behavior go unchecked. Your questions will be answered by experts in the Office of the General Counsel to assess potential breaches of the Code of Business Conduct and whether they should be further investigated.
The EthicsPoint system and report distribution are designed so that only designated persons in the Office of General Counsel will receive the reports in the first instance. The purpose of the Hotline is to permit you to report in confidence potential violations of the Code of Business Conduct when you are not comfortable reporting to your direct supervisor or local management, for example because the relevant persons locally might be implicated in the report. Those implicated parties are not granted access to reports in which they have been named.
When you file a report on the Firm's EthicsPoint Internet / web portal page or through the EthicsPoint call center, you will receive a unique username and be asked to choose a password. You can return to the EthicsPoint system again either by Internet / web portal or telephone and access the original report to add further information that will help resolve open issues. If more information is sought of you, we ask that you return to the site in the time specified to provide it.
Yes. All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity, provided anonymity is permitted under local laws and regulations.