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 that enables management and employees to work together to address any actions or behaviors that contravene the Company’s Code of Conduct or its values (e.g. fraud, abuse and other misconduct, grievance, health and safety, etc.), while cultivating a positive work environment.

Why do we need a system like EthicsPoint?

Reporting – General

May I report using either the Internet or the telephone?

Yes. EthicsPoint enables you to report confidentially any concerns that you may have while choosing to remain anonymous either through telephone or the web.

What types of situations should I report?

Employees have a duty to raise questions or concerns about the Code of Conduct or events that might infringe the Code, Policies and Procedures, the law, or anything that may put the company at risk. These concerns could relate to something you have been asked to do, a situation you are faced with, or the conduct of people around you.

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

When you observe some behaviors or events that you believe violates our Code of Conduct, we encourage you to report it. Ideally, you should report any alleged violation or concerns to your line manager or your Human Capital Business Partner or your Ethics Panel member. However, there may be instances when you are not comfortable reporting the alleged issue to your line manager or to a member of the ethics panel and would wish to remain anonymous, in these cases you are encouraged to use our external confidential Ethics hotline (EthicsPoint by NAVEX) to report it.

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

We all have the right to work in a healthy environment and with that comes the responsibility of acting in an ethical manner and letting the relevant people know if someone is not acting appropriately or violating our Code. We believe in building sustainable businesses to positively impact the countries in which we operate. We can only achieve this if our growth is based on a moral imperative to conduct ourselves with integrity and uncompromising ethics.

Does management really want me to report?

Yes, we certainly need you to report any behaviors or events that you believe violates our Code of Conduct. Doing this will not only protect the welfare and safety of our employees, but also our operations and reputation.

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 authorized personnel at Majid Al Futtaim who are responsible for evaluating the report, based on the type of violation and location of the incident. All allegations are dealt in full confidentiality by the relevant Operating Company Ethics Panel members and in compliance with applicable laws from report intake to resolution.

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

No. EthicsPoint is a safe and secure mechanism to report any concerns that you may have regarding issues arising within your workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern. Speaking up in confidence and good faith, with no fear of retaliation or reprisal, is crucial to a healthy working environment, welfare and safety of our employees, operations and our reputation.

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 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 reporting through your work PC, you have the option of using a PC outside of work environment (such as one located at an Internet café or at a friend’s house) through the EthicsPoint secure website. NAVEX’s data reveals that less 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.

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

The EthicsPoint system protects your anonymity. However, if you wish to remain anonymous as a reporting party, you 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 a web-based report and an interviewer (hotline representative) will type your responses into the EthicsPoint Web site. These reports have the same security and confidentiality measures applied to them.

What if I want to be identified with my report?

There is a specific 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 is committed to the highest degree of honesty and ethical behavior. We believe in building sustainable businesses to positively impact the countries in which we operate. This commitment has seen us build a formidable reputation that no business or profit can ever justify putting at risk. As such, it is your duty to report any incidents of misconduct or ethical violations to safeguard the welfare and safety of yourself and your colleagues, as well as our operations and reputation.

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 analyzed. We'd rather need you to report a situation that turns out to be harmless than let possible unethical behavior go unchecked.

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 will ensure 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 using the EthicsPoint Web site or the EthicsPoint Call Center, you receive a unique, randomized number called a “Report Key” and then asked to choose a password. You can return to the EthicsPoint system again either by webpage or telephone and access the original report using this report key and password to add more details or answer questions posted by your company representative. We strongly recommend you provide all details or clarify the queries requested by your company within the time specified to facilitate a proper investigation and case closure. You and your company now have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved.

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

All EthicsPoint correspondences are held in strictest confidence as the initial report, continuing under the umbrella of anonymity.

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. However, mention in the new report that it is related to a report or question that you had previously submitted.

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

You can file an EthicsPoint report using web from any computer that can access the Internet. If you don’t have access to or feel uncomfortable using a computer, you can call the EthicsPoint toll-free hotline, which is available 24 hours a day, 365 days a year.