About EthicsPoint

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX that enables management and employees to work together to address issues of concern in the workplace while cultivating a positive working environment.

Why do we need a system like EthicsPoint?

By creating open channels of communication, we promote a positive work environment and maximize productivity. Everyone should feel comfortable about speaking up about things they experience – or see others experiencing – which do not fit with our desired working culture here at Kantar.

Specifically, an effective reporting system assists our other efforts to foster a culture of integrity and ethical decision-making.

Reporting – General

May I report using either the Internet or the telephone?

Yes. EthicsPoint enables you to file a confidential and, if appropriate, an anonymous report via either the telephone or the Internet. You can also file a report by accessing the NAVEX portal on your mobile phone

What types of situations can I report?

The EthicsPoint system allows employees to report any concerns they have about the way that Kantar operates and conducts its business. This includes concerns about any suspected danger or wrongdoing including any actual or suspected breach of Kantar Business Principles, the Kantar Policy Book and applicable laws or regulatory requirements. This could include reporting any of the following, but please note that this isn’t an exhaustive list.

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 Kantar Business Principles, the Kantar Policy Book, the law or our regulatory requirements, we encourage you to report it. If the issue affects you personally, you may wish to raise your concern with your direct manager or other member of our management team or Human Resources. However, we appreciate and understand that there may be circumstances when you are not comfortable reporting the issue in this manner given the specific nature and/or gravity of your concern. It is for these kind of situations that Kantar provides an entirely independent process for raising reports via our independent Global Right to Speak Reporting Service and Helpline (EthicsPoint).

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.

Also, sticking to our beliefs and principles isn’t just the right thing to do – it’s vital to the continued long-term success of Kantar. Failure to do so endangers the health of Kantar as a business, and the good corporate reputation we all work so hard to build. Finally, Kantar wants to provide you with the right guidance to protect yourselves as employees too.

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 or a suspicion of an activity that may be cause for concern that management is unaware of. Your reporting can minimize the potential negative impact on Kantar our business, people and culture. Making a report about an issue which is causing you concern can therefore result in improving our corporate culture and performance.

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPoint secure server. NAVEX makes these reports available only to specific individuals within Kantar who are charged with evaluating the report, based on the nature and location of the incident and/or the reporter. In most jurisdictions reports are initially reviewed and assessed by our central investigations team unless local law stipulates otherwise. Kantar’s Global Right to Speak Policy and any supplementary guidance notes will clarify who has access to the reports, where local law requires a different approach to that outlined in these FAQs. In some instances, it may be appropriate to appoint an external resource to investigate or refer the matter to an external body such as a regulator or law enforcement.

Unless it is inappropriate due to the nature of the report and the identity of the alleged perpetrators, most reports are passed to appropriate individuals in the market or region to which the concern relates to investigate. The outcome of any investigation, recommended remedial action and follow up is then shared with the central investigations team. This may be subject to employee consent in markets where this is necessary. If the reporter has a particular concern about this approach, they should specify this at the time of making their report.

Reports are not investigated by Ethicspoint or NAVEX (the company that operates this service). Ethicspoint is merely the independent and confidential platform through which reports can be made.

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

No. EthicsPoint is a positive aspect of our overall philosophy that allows us to ensure 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, Ethicspoint, 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 website that my PC connects with. Won’t this log identify me as the report originator?

NAVEX does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available.

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 or at a friend’s house) through the EthicsPoint secure website. Many people choose this option, as NAVEX’s data shows that fewer than 12% of reports are generated during business hours. There is also the option to use the NAVEX hotline.

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

Kantar is committed to ensuring that employees feel empowered to raise concerns openly under Right to Speak, without fear of reprisal, retaliation or victimization and with the support of Kantar. A report from home, a neighbour’s computer, or any internet portal will remain secure, and anonymous should you so wish. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is totally maintained.

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 protects your anonymity should you so wish. 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 a case handler 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?

That is absolutely fine. Where appropriate, and subject to local law restrictions, we encourage reporters to provide their contact details if this is possible. There is a section in the report to identify yourself, if you wish.

Tips & Best Practices

I am aware of some individuals acting unethically, but it doesn't affect me. Why should I bother reporting it?

Our company promotes ethical behavior. All unethical conduct, at any level, could ultimately damage Kantar and its employees, suppliers and clients, including you. You only have to consider what happened in recent corporate scandals to see the disastrous effects that a lapse in ethics can have on an otherwise healthy company. If you know of any incidents of misconduct or unethical conduct, we encourage you to report it. That way the issue is brought to our attention, which then enables us to take appropriate steps to address 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. NAVEX 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. Individuals making a report do not need to show absolute proof of their suspicions in order to raise a report via NAVEX. They must, however, have reasonable grounds to believe, given the circumstances and the information available to them at the time of reporting, that the matters they are reporting are true.

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 ensure that implicated parties who are identified in the report 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 Kantar has further questions for me concerning my report?

When you file a report at the EthicsPoint Web site or through the EthicsPoint Call Centre, you receive a unique, randomized number called a “Report Key” and you 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 at any time by using the Report Key and passcode. We strongly suggest that you return to the site regularly to answer any questions which may have been posted. This is particularly important for anonymous reports. You and Kantar now have entered into an “anonymous dialogue,” where you can confidently respond to follow up questions.

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

All EthicsPoint communications are treated in the same strict confidence as the initial report. If you have chosen to be anonymous then your anonymity will be respected in any follow up.

What if I lose my Report Key or forget the Password I created?

To ensure that security and confidentiality is maintained, if you lose your report key or password, you will need to file a new report. Mention in the new report that it is related to a report or question you previously submitted.

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

You can file an EthicsPoint report from any computer or mobile telephone that can access the Internet. You can file from home. Many public locations, including the public library, have internet connected computers. Alternatively , you can call the EthicsPoint toll-free hotline, which is available 24 hours a day, 365 days a year. You will be put through to a local language call handler. They will ask you a series of questions and will document your responses into a report which will be uploaded onto the EthicsPoint portal.