EthicsPoint is a TITAN Group internal reporting channel provided by our third party NAVEX where employees and business collaborators can report work related concerns with confidentiality, to address fraud, abuse, breach of EU laws, and other misconduct in the workplace and promote ethical behavior. Concerns can be reported by phone or online.

• By creating open channels of communication, we can promote a positive work environment.
• An effective reporting platform will complement efforts to foster a culture of integrity and ethical decision-making.

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

The EthicsPoint platform is designed for employees and business collaborators to report any incident that might constitute or related to a violation of Titan Group’s Code of Conduct, Purpose & values and internal policies, a breach of EU Law , or other concern they may have. The categories you can report a concern for are:

• Accounting, Auditing and Financial Reporting
• Business Integrity
• Environment, Health and Safety
• Misuse or Misappropriation of Corporate Assets
• People, Diversity and Workplace Respect
• Breaches of EU Law

Examples of specific incidents are provided when filing a report.

When you observe any Incident, as specified above, we expect you to report it by choosing any of the established reporting channels, set forth by the Group Whistleblowing Policy, including EthicsPoint platform. You may also notify management or the designated departments.

We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical and lawful manner and letting the company know if someone is not acting appropriately. By working together, we can maintain a positive and productive environment.

Certainly. 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 your input may help identify issues that can improve corporate culture and performance.

Reports are entered directly on NAVEX’s EthicsPoint secure server to prevent any possible breach in security. EthicsPoint makes these reports available only to the relevant TITAN Group’s assigned committees, comprising of Group and Regional Executives, who are entitled to evaluate the report, based on the type of violation and location of the incident. Each of these report recipients has received training in keeping these reports in the utmost confidence.

It is essential to provide sufficient detail while making a report, including relevant facts, dates, locations, and names of individuals involved, if known. The more specific and accurate the information, the better it will assist TITAN Group’s assigned committees in addressing the issue.

Yes, EthicsPoint platform allows you to attach files, such as documents or images to support your report. This can help provide additional evidence or context for better investigation.

If you provide your name when you report your concern, the TITAN Group assigned committee will be able to better follow up and further investigate it. So, we encourage you to do so. However, you have the option to report your concern anonymously. In both cases, the reports carry the same importance and are treated with the same, high level of confidentiality.

There is a section in the report where you can provide your name, telephone and e-mail if you wish.

EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so there is no information linking your PC to EthicsPoint. In fact, EthicsPoint is contractually committed not to pursue a reporter’s identity.

If you feel uncomfortable filing a report on your work PC, you have the option of using a PC outside our work environment (such as your personal computer, one located at an Internet café or at a friend’s house, etc.) through the EthicsPoint secure portal. Many people choose this option, as EthicsPoints’ data shows that fewer than 12% of reports are generated during business hours.

A report from any computer - your work or home computer, a neighbor’s or a public computer - will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint platform strips away Internet addresses so that anonymity is secured. Plus, NAVEX is contractually committed not to pursue a reporter’s identity.

The EthicsPoint portal is designed to protect your anonymity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that you do not provide details at the report, which could reveal your identity by accident. For example, “From my office next to Jan Smith…” or “In my 33 years in the company…”.

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and a NAVEX interviewer will type your responses into the EthicsPoint portal. These reports have the same security and confidentiality measures applied to them during delivery.

Our company chooses to promote ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. You can consider what happened in recent corporate scandals to see the disastrous effects that a seemingly harmless lapse in ethics can have on an otherwise healthy company. So if you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it.

In case of doubt as to whether a report should be made, you are encouraged to contact your manager or the departments or persons designated to receive reports, or to use the functionality of asking questions through the EthicsPoint reporting platform.

We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you weren't sure.

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.

When you file a report, either anonymously or by providing your name, at the EthicsPoint portal or through the EthicsPoint toll-free telephone number, you receive a Report Key and are asked to choose a password. You can return to the EthicsPoint platform again either by Internet or telephone and access the original report to answer questions posed by the company representative or to add further information that will help resolve open issues. We strongly suggest that you return to the site in the time specified to answer company questions. You and the company now have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex. You may also use the same credentials to receive updates and follow up on the outcome of your report evaluation.

All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

To file a Report online, through the EthicsPoint portal, you need to have access to the internet. Alternatively, you can call the EthicsPoint toll-free telephone number, which is available 24 hours a day, 365 days a year.