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

About EthicsPoint

  1. What is EthicsPoint?
  2. EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX, independent of Labcorp, to enable both Labcorp management and employees to work together to address actual or suspected violations of Labcorp’s Code of Conduct and Ethics, policies, applicable laws and regulations.

  3. Why do we need a reporting tool like EthicsPoint?
  4. At Labcorp, our employees are our most important asset. By creating open channels of communication and a “Speak Up” culture, we promote a positive work environment, a workforce that acts with integrity and respect and maximizes productivity. Publicly traded companies, like Labcorp, are required by law to have an anonymous and confidential reporting tool to address accounting and auditing fraud directly to the audit committee. An effective reporting tool empowers our employees and augments our efforts to foster a culture of integrity and ethical decision-making.

Reporting – General

  1. May I report using either the online or telephone reporting options?
  2. Yes. With EthicsPoint, you have the ease to make a confidential and, where appropriate, anonymous report online or by telephone. There is no cost to you to make a report by telephone from any location. Each of the published telephone numbers is toll-free from the locations in which Labcorp conducts business. The Call Centre, operated by NAVEX, is independent of Labcorp, and is open 24 hours, 365 days a year.

  3. What types of concerns should I report?
  4. Labcorp encourages its employees to report any concern which is harmful to the company, its employees, its brand and reputation or where you see or hear something that is plainly wrong. Typically, this will include non-compliance with Labcorp’s Code of Conduct and Ethics, policies, applicable laws and regulations and examples, include issues involving regulatory and compliance, human resources, quality, environmental health & safety, workplace security, IT security, data privacy, animal welfare, fraudulent financial transactions, theft or misuse of Labcorp resources, conflicts of interest, and violations of internal accounting records.

  5. If I see a violation, shouldn't I just report it to my manager, security, or human resources and let them deal with it?
  6. Labcorp encourages its employees to discuss and escalate concerns to their line managers or supervisors in the first instance. We recognize, however, that there may be circumstances when you are not comfortable reporting the concern in this manner. You can also report directly to your HR personnel, Country or Department Heads, Compliance Liaisons or Officers, Corporate Compliance Department, Internal Audit, Law Department, General Counsel and/or Chief Legal and Compliance Officer.

    In addition to these direct and open door reporting options, employees are able to report through EthicsPoint and especially where they choose to remain anonymous. We would rather you report your concerns anonymously than keep the information to yourself.

  7. Why should I report what I know? What’s in it for me?
  8. At Labcorp, all employees have the right to work in a positive environment, with respect, ethics, and integrity. As employees, we expect you to “do the right thing” and report concerns in a proactive manner and without delay. By remaining silent or turning a blind eye, you will likely cause more harm to Labcorp and its employees. Labcorp’s management needs your help and assistance to identify, investigate and remediate misconduct. Together we can make a difference and accomplish Labcorp’s mission to “improve health and improve lives”.

  9. Does Labcorp management really want me to report?
  10. Yes. Labcorp’s leadership team and its Board of Directors fully endorse this reporting tool and encourage you to report in good faith not only actual violations but also those where you reasonably suspect a violation or misconduct. Labcorp has an internal investigations policy coupled with trained individuals and tools to investigate concerns. Each of our employees is critical to keeping us fully informed on what is going on within our business across our 75,000 employees and operations in over 100 countries.

  11. Where do these reports go? Who can access them?
  12. Reports are entered directly onto the EthicsPoint secure server (which is separate to Labcorp’s servers) to prevent any possible breach in security. EthicsPoint makes these reports available only to authorized individuals within Labcorp who are trained to evaluate the reports (based on the type of violation and location of the incident), maintain confidentiality and escalate it through the appropriate channels. The identity of the reporter and the information disclosed is treated confidentially and disclosed on a need to know basis, for example, to complete an internal investigation or where required by law.

  13. I suspect a misconduct, but I cannot prove it. Should I report it through the reporting tool?
  14. Yes. Where you reasonably and in good faith suspect a violation or misconduct, you are encouraged to report it and provide as much detail as possible to enable Labcorp investigators to look into the matter. It is not necessary for you to investigate the violation or misconduct.

  15. Do I need to disclose my identity (i.e. provide my name, email or telephone contact details)?
  16. No. You can choose to remain entirely anonymous but you should assist Labcorp investigators by frequently logging into the reporting tool by the Report Key and your password so that we can ask any follow up or clarifying questions. At Labcorp, we encourage our employees to provide their names and contact details so that they can be contacted directly for follow up and assistance. Your identity will remain confidential.

  17. I do not speak English. Can I speak to someone and/or make an online report in a language other than English?
  18. Yes. NAVEX call centers are staffed by multilingual speakers. Live telephone language interpretation is available in 150+ languages. Similarly, online reports in a non-English language is professionally translated and available to Labcorp in both the native and English languages.

  19. What happens if someone retaliates against me for making a report?
  20. Labcorp prohibits retaliation in any form against an individual or entity for reporting in good faith any actual or suspected violations of Labcorp Code of Conduct and Ethics, policies and applicable laws and regulations. This includes assisting with investigations and/or disciplinary proceedings including as a witness, subject matter expert, subject or investigator. Any Labcorp employee engaged in retaliatory behavior shall be subject to disciplinary action, up to and including termination of employment.

  21. Does Labcorp have an Investigation Policy? And, how does Labcorp investigate allegations?
  22. Labcorp has an internal investigations policy (BPM-13), and a framework for conducting internal investigations with appropriately trained investigation personnel.

  23. Does Labcorp take appropriate disciplinary action against individuals who have violated the Labcorp Code of Conduct and Ethics, policies or generally misbehaved towards others (i.e. harassment, bullying or retaliation)?
  24. Yes. Labcorp has HR policies and disciplinary action procedures and will take appropriate steps to remediate any misconduct, and where appropriate, take disciplinary action as required.

Reporting Security & Confidentiality

  1. It is my understanding that any report I send from a Labcorp computer generates a server log that shows every website that my computer connects with. Will this log identify me as a report originator?
  2. 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 computer, you have the option of using a computer or other device outside of the work environment.

  3. Can I make a report from home and still remain anonymous?
  4. 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 the anonymity of a reporter is maintained. EthicsPoint is also contractually committed to not pursue a reporter’s identity.

  5. I am concerned that the information I provide EthicsPoint will ultimately reveal my identity. How can Labcorp assure me that will not happen?
  6. 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, “I sit opposite David”.

  7. Is the telephone toll-free hotline confidential and anonymous too?
  8. Yes. You will be asked to provide the same information that you would have provided in an online report. The NAVEX call handler will type your responses into the EthicsPoint website. Reports, whether by telephone or online, have the same security and confidentiality measures applied to them during delivery.

  9. What if I want to be identified with my report?
  10. This is Labcorp’s preference. It will enable us to investigate your concerns with an open communication channel. There is a section in the report for providing your details, if you so wish.

Tips & Best Practices

  1. I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?
  2. Labcorp promotes ethical behavior. All unethical conduct, at any level, ultimately hurts Labcorp and its employees, including you. You only have to consider recent corporate scandals to see the adverse impact that a lapse in ethics can have on a business. If you know of any violations or misconduct, it is your duty to Labcorp, your coworkers and yourself to report it proactively and promptly.

  3. I am not sure if what I have observed or heard is a violation of Labcorp policy, or involves unethical conduct. It just does not look right to me. What should I do?
  4. Make a report – if it does not look or feel right, the chances are, it is not right. At Labcorp, we rather you were overcautious and report a situation that turns out to be harmless than let suspected unethical behavior go unchecked because you were not sure.

  5. What if my manager and superiors are involved in a violation? Won’t they get the report and start a cover-up?
  6. The EthicsPoint system and report distribution process is designed so that implicated parties are not notified or granted access to any reports in which they are named.

  7. What if I remember something important about the incident after I make a report? Or, what if Labcorp has further questions for me concerning my report?
  8. When you make a report through the website or Call Center, you receive a unique Report Key and you create your own password. You can return to the EthicsPoint system either through the website or call center to access the original report and to add more detail, answer questions raised by Labcorp investigators or provide evidence to support the investigation. Labcorp recommends that you frequently return to the reporting tool to answer questions or provide further assistance. You and Labcorp will have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

  9. Are these follow-ups on reports as secure as the first one?
  10. All EthicsPoint communication is held in the same strict confidence as the initial report, and where selected, continuing under anonymity.