About the EthicsLine

What is the EthicsLine?

The EthicsLine is a comprehensive and confidential reporting tool created by NAVEX and brought to you by EthicsPoint to assist management and employees work together in addressing fraud, abuse, and other misconduct in the workplace, all while cultivating a positive work environment.

Why do we need a system like the EthicsLine?

  • We believe that our employees are our most important asset. By creating open channels of communication, we can promote a positive work environment and maximize productivity.
  • Publicly traded companies may be required by law to have a reporting vehicle to address accounting and auditing fraud directly to the audit committee.
  • An effective reporting system will augment our further efforts to foster a culture of integrity and ethical decision-making.

Reporting – General

May I report using either the Internet or the telephone?

Yes. With the EthicsLine you have the ability to file a confidential report via either the telephone or the Internet.

The EthicsLine is designed for employees to report any violation of our stated Code of Conduct, or other concern you may have.

Please note: the scope of issues and concerns you may report via the EthicsLine may vary by country due to local regulations.

If I see a violation, shouldn't I just report it to my manager, security, or human resources and let them deal with it?

When you observe some behavior that you believe violates our code of conduct, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager, or other member of our management team. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that we have partnered with EthicsPoint.

You are strongly encouraged you to identify yourself when making a report. Failing that, we would rather you report anonymously than keep the information to yourself.

Why should I report what I know? What’s in it for me?

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 letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the livelihood of an entire company.

Does management really want me to report?

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 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.

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.

In some countries the company may be required to inform each person implicated in a report and/or provide them with a copy of the information contained in the report.

Isn’t this system just an example of someone watching over me?

The EthicsLine concentrates on being a positive aspect of our overall philosophy, and allows us to assure a safe, secure, and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern. Effective communication is critical in today’s workplace and this is a great tool to enhance that communication.

We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment.

Reporting Security & Confidentiality

It is my understanding that any report I send from a company computer generates a server log that shows every web-site that my PC connects with, and won’t this log identify me as a report originator?

The EthicsPoint system does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available. In fact, EthicsPoint 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 EthicsPoint secure website. Many people choose this option, as EthicsPoint’s data shows that fewer than 12% of reports are generated during business hours.

Tips & Best Practices

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

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.

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

Whilst it is not mandatory, you are strongly encouraged to file a report. The EthicsLine can help you 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 operators of the EthicsLine will assist you in identifying whether your concern is suitable for a report under local regulations.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The EthicsLine system and report distribution themselves are designed so that implicated parties are not notified or granted access to reports in which they have been named.

As part of the company's investigation and where required by local regulations, the company may have to inform each person implicated in a report and/or provide them with a copy of the information contained in the report.

The company will not tolerate any “cover-up” of a violation or detrimental treatment of, or retaliatory action against any employee who raises a genuine concern in accordance with the company’s SpeakUp Manual (even where no malpractice is found). The company will take appropriate steps to protect such employees in line with applicable local law.

What if I remember something important about the incident after I file the report? Or what if the company has further questions for me concerning my report?

When you file a report within the EthicsLine, you receive a unique user name and are asked to choose a password. You can return to the EthicsLine system 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.

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

All EthicsLine correspondences are held in the same strict confidence as the initial report.

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

You can file an EthicsLine report from any computer that can access the Internet. You can file from home. Many public locations, including the public library, have Internet computers. If you don’t have access to or are uncomfortable using a computer, you can call the Ethics Line toll-free hotline, which is available 24 hours a day, 365 days a year.