To prevent and tackle any potential misconduct (corruption, data privacy, labor issues, health and safety and breach of policies, among other concerns) in the workplace – all while cultivating a positive work environment – we have implemented an ethical alert channel. This alert channel is a comprehensive and confidential reporting tool created by NAVEX, a third party service provider, by means of which you can report any concern anonymously (if you choose so), via the Internet (online) or through the telephone toll-free number.
We expect you to report any violation of our Code of Conduct, Policies, potential fraud, abuse, and other misconduct you may witness or be victim of, such as competition practices, bribery and corruption, accounting and/or financial matters, safety of people or to the environment, abuse or behavior (discrimination and harassment), fraud, data protection, conflict of interest, etc.
You have the ability to file a confidential, anonymous (if you choose so) report via either the telephone or the Internet.
You can bring any concerns forward to your direct manager, or other member of our management, legal and/or human resources teams. If you don’t feel comfortable in doing so or want to report anonymously, you can now do it through the alert channel.
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 reporting through the appropriate channels a particular situation or misconduct. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the livelihood of an entire company, and conflicts with our views and values.
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 the initial knowledge of an activity that may be a 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.
Reports are entered directly on a secure server to prevent any possible breach in security and anonymity (if that is your choice). These reports are made 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.
The alert channel does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to the alert channel is available. In fact, the third party service provider, NAVEX, 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 our work environment (such as one located at an Internet café, at a friend’s house, etc.) through the secure website. Many people choose this option, as data shows that fewer than 12% of reports are generated during business hours.
A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous (if you choose to do so). An Internet portal never identifies a visitor by screen name and the system strips away Internet addresses so that anonymity is totally maintained. Plus, NAVEX is contractually committed not to pursue a reporter’s identity.
The alert channel is designed to protect your anonymity. However, if you wish to remain anonymous, you – as a reporting party – also need to ensure that the body of the report does not reveal your identity by accident. For example, “From my cube next to Jan Smith…” or “In my 33 years…”.
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 Web site. These reports have the same security and confidentiality measures applied to them during delivery.
There is a section in the report for identifying yourself, if you wish.
Our company chooses to promote ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. You only have to 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.
File a report. Through the filing you will receive help to 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 behavior go unchecked because you weren't sure.
The alert channel 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 through the website or through the telephone toll-free number, you receive a unique user name and are asked to choose a password, as all communications between you and us will be done through this channel and on an anonymous basis. You can return to the alert channel 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 in the time specified to answer company questions.
All correspondences through the alert channel are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.
You can file an online report from any computer that can access the Internet. If you don’t have access to or are uncomfortable using a computer, you can call the telephone toll-free number, which is available 24 hours a day, 365 days a year.