About EthicsPoint Reporting – General Reporting Security & Confidentiality Tips & Best Practices

About EthicsPoint

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX to assist management and employees to 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 EthicsPoint?

  • 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.
  • NYK Group is committed to the highest standards of ethical, moral, statutory compliance and legal conduct in operating its businesses. In line with this commitment, this system is intended to provide a mechanism for employees to raise concerns where the interest of the organization is at risk.
  • This system provides the ways and means by which employees can confidentially report improper, illegal or unethical behavior.
  • The Company assures that employees raising such concerns will be protected from reprisals or victimizations.

An effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision-making.

Reporting – General

Why Implement a Helpline?

  • To proactively detect and address misconduct
  • To identify areas that might need improvement
  • To reinforce an ethical corporate culture
  • To comply with laws and regulations
  • To encourage internal reporting of concerns
  • To mitigate fines and penalties

What is the objective?

  • To remove all possible barriers to reporting
  • Provide a variety of channels that:
    • Are free to use
    • Provides anonymity, if opted
    • Are easily accessible
    • Are available 24 hours a day, 365 days a year
    • Facilitate two-way communication with the reporting party/employee and NAVEX
  • Support from Senior Management:
    • Embraces and understands whistleblowers /reporters
    • Designates a Top Management-level helpline champion/subscriber
    • Addressing and Understanding International Differences
    • Legal and regulatory issues; Language barriers; Cultural differences

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 NYK Group/Individual Company’s Code of Conduct, or other concern you may have.

All employees, customers, service providers, contractors or consultants are encouraged to report concerns, if any. It is intended to address all serious matters, including, but not limited to:

  • Antitrust
  • Bribery
  • Fraud and Embezzlement
  • Conflict of Interest
  • Dishonest, Fraudulent, Inappropriate, Corrupt or Illegal behavior;
  • Bullying, Harassment, Discrimination, Retaliation, any Misconduct or other Improper Conduct in the workplace;
  • Accounting, Books & Records or Internal Control matters;
  • Improper Conduct or Unethical Behavior;
  • Disclosure of Confidential Information and Misappropriation
  • Conduct endangering health or safety;
  • Conduct endangering the environment;
  • Solicitation or acceptance of cash, gifts or favors to perform a function, which the employee is required by the job description to perform (e.g., accepting gifts or money from a supplier in order to gain additional business);
  • Improper Supplier or Contractor Activity
  • Misuse of Company Benefits;
  • Taking of money or money instruments from the premises of the Company without authoritative permission;
  • Offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust;
  • Any other improper activities that may have a negative impact upon the ability of the Company to achieve its corporate objectives and which may cause damage to its image and reputation;
  • Time Abuse
  • Unsafe Working Conditions
  • Workplace Violence
  • Data Privacy
  • Sexual Harassment
  • Any act or omission in violation of the Company’s Code of Conduct, values and other Policies of the Company
  • Suppression of concealment of any information relating to the above
  • Others.

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 the Code of Conduct, Company Policy or the Law, we expect and urge 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.

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.

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

The EthicsPoint system 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?

EthicsPoint 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.

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 EthicsPoint system strips away Internet addresses so that anonymity is totally maintained. Plus, EthicsPoint is contractually committed not to pursue a reporter’s identity.

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

The EthicsPoint 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…”.

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 EthicsPoint 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 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?

File a report. EthicsPoint 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 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.

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 EthicsPoint Web site or through the EthicsPoint Call Center, you receive a unique user name and are asked to choose a password. You can return to the EthicsPoint 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. 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 EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

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

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