About Quadient Ethics Line

1. What is EthicsPoint and how does it relate to Quadient Ethics Line?

EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX Global that we have named “Quadient Ethics Line” within our company. NAVEX Global will assist management and employees to work together in addressing fraud, abuse, and other misconduct in the workplace, all while cultivating a positive work environment.

2. Why do we need a reporting system like Quadient Ethics Line?

- 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 are required by law to have an anonymous reporting vehicle to address accounting and auditing fraud directly to the audit committee.
- An effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision-making.

3. Why should I report ethical concerns to the company?

At Quadient, 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 for all employees in every business and in every geography. Corporate misconduct can threaten the livelihood of an entire company.

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

Quadient 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.

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

You can file a Quadient Ethics Line 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 Quadient Ethics Line toll-free hotline, which is available 24 hours a day, 365 days a year.

6. How do I contact the Ethics & Compliance Committee or my regional Compliance Officer with my questions about the Code of Ethics?

Please consult our Code of Ethics and the following link that will provide you with the names and contact information for your regional Compliance Officer and for members of the Ethics & Compliance Committee.

Reporting a concern

7. May I report using either the Internet or the telephone?

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

8. What type of situations should I report?

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

9. What if the situation I am reporting is an emergency?

Concerns about an immediate threat of physical harm or damage to property should not be reported to EthicsPoint. Instead, please contact your local emergency services.

10. How does Quadient investigate concerns?

Ethics concerns are reported either on-line or via telephone through the Quadient Ethics Line. The Ethics & Compliance Committee is notified of all reports. The Committee forwards reports to the appropriate regional Compliance Officers and their investigation teams. In accordance with local regulations and Company practices, an investigation will be conducted. All investigations will be conducted in an objective, timely and thorough manner. Reporters may check the status of the investigation by clicking the Follow Up link on the Quadient Ethics Line website.

11. 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 Ethics, 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. We would rather you report anonymously than keep the information to yourself.

12. 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?

Please consult at first our Code of Ethics and policies. If you are still unsure, please file a report. 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.

13. 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 through the Quadient Ethics Line website or hotline, you receive a unique report key and are asked to choose a password. You can return to the system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a company investigator and add further information that will help resolve open issues.

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

The Quadient Ethics Line system, its report distribution and investigations process are designed so that implicated parties are not notified or granted access to reports in which they have been named.

15. What if I have concerns about retaliation?

Quadient strictly forbids retaliation against employees for submitting an ethics concern to the Company. Complaints made in good faith will not expose you to any sanctions, regardless of whether the underlying facts prove to be correct or result in any corrective action. If you believe you have been subjected to retaliation for your ethics complaint, please report it to a Compliance Officer or through the Quadient Ethics Line so that the Company may investigate and take appropriate action. Employees who knowingly provide false or misleading information to the Company may be subject to discipline.

Security & Confidentiality

16. 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?

Quadient Ethics Line does not generate or maintain any internal connection logs with IP addresses. There will be no information linking any computer to Quadient Ethics Line. If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside your work environment such as one located at an Internet café, at a friend’s house, etc.

17. Where do these reports go? Who can access them?

Reports are entered directly on the NAVEX Global secured server to prevent any possible breach in security. Quadient Ethics Line makes these reports available only to compliance officers and investigators within the company who are charged with evaluating the report, based on the type of violation and location of the incident. Certain executive leaders may have access to statistics and reports if required.

18. 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 Quadient Ethics Line Web site. These reports have the same security and confidentiality measures applied to them during delivery.

19. 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 Quadient Ethics Line strips away Internet addresses so that anonymity is totally maintained. Plus, NAVEX Global is contractually committed not to pursue a reporter’s identity.

Note: Please consider that the anonymity feature may not be available in certain countries due to local regulations. In this event, the ability to remain anonymous will not display.

20. What types of personal data and information will be collected and processed?

If you report an incident to the Quadient Ethics Line, the following personal data and information will be requested:

> Your name and your contact information (unless you choose to report anonymously);
> Whether you are employed by Quadient
> The name and Company location of the persons you name in your report (if you include such information to enable an effective investigation); and
> A factual description of the misconduct as well as a description of the circumstances surrounding the incident.

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

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