FAQs

• Reporting – General
• Reporting Security & Confidentiality
• Tips & Best Practices

What is EthicsPoint?

Reporting – General

May I report using either the Internet or the telephone?

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

What type of situations should I report?

The EthicsPoint system is designed for employees to report any violation of our stated Code of Conduct, or other concern you may have about reasonably held beliefs that a wrongdoing has been, is being or is likely to be committed.

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 line manager, HR representative 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 are introducing our Speak Up service. We want to be sure you have every opportunity to raise concerns about reasonably-held beliefs of wrongdoing through a variety of channels. This policy does not replace our regular reporting lines or complaints procedures, but should you reasonably believe that a wrongdoing has been, is being or is likely to be committed, we encourage you to use this service, so the issue can be dealt with appropriately.

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 wrongdoing can threaten the livelihood of an entire company and everyone who works for it.

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 (an independent company, which hosts the Speak Up service) 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.

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

No, we believe the Speak Up service is actually someone looking out for you, our other employees and the Group itself. It is a voluntary and confidential service, which allows people at every level of the organization to contribute towards creating a supportive work environment, which enables us to conduct our business with fairness, integrity and respect for the law and our values.

The Speak Up service 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?

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

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the Speak Up system strips away Internet addresses, so that anonymity is totally maintained. Plus, the Speak Up service is contractually committed not to pursue a reporter’s identity.

I am concerned that the information I provide Speak Up will ultimately reveal my identity. How can you assure me that will not happen?

The Speak Up 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 cube next to Jan Smith…” or “In my 33 years…”.

The information about your concerns will only be shared with a limited number of people on a strict need-to-know basis. Information will only be disclosed outside this small group or if we are required to do so by law, a governmental body or agency, a regulatory Code of Conduct or by a Court or Tribunal. In some cases, you may be called upon by a Court or other Tribunal to give evidence regarding the subject matter of the report.

Is the telephone toll-free hot line confidential and anonymous too?

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 Speak Up web site. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the report for identifying yourself, if you wish.

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 is committed to promoting 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 wrongdoing 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?

File a report or ask your question online or by phone. Speak Up 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.

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

The Speak Up system and the distribution of any reports from it, are designed so that implicated parties are not notified or granted access to reports in which they have been named.

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 at the Speak Up website online or by phone, you receive a unique user name and are asked to choose a password. You can return to the Speak Up system again, either by Internet or telephone and access the original report to add more detail or answer further questions, which the company might have to 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.

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

All Speak Up correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity, where at all possible.

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

You can file a Speak Up 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 Speak Up toll-free hotline, which is available 24 hours a day, 365 days a year.