EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX to assist management and employees work together in addressing fraud, abuse, and other misconduct in the workplace, all while cultivating a positive work environment.

• Our employees are our most valuable asset. By encouraging employees to speak up, we can foster a positive work environment and boost productivity.
• Corporate Governance standards require companies to have an anonymous reporting vehicle to address ethics and compliance related matters to the Audit and Risk Committee.
• An effective reporting system will complement our other efforts to create a culture of integrity and ethical decision-making.

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

The EthicsPoint system is designed for employees to report any violation of our Code of Conduct or what appears to be wrongdoing.

We expect you to report any behavior that you believe violates our Code of Conduct. Ideally, you should bring your concerns to your direct manager or another member of our management team. However, we understand that there may be circumstances when you are not comfortable reporting the issue in this way. If this is the case, you can report the issue anonymously through EthicsPoint. We would rather you report anonymously than keep the information to yourself.

We all have the right to work in a positive environment. With this right comes the responsibility to act ethically and report any inappropriate behavior to the appropriate people. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the livelihood of an entire company.

We certainly do. We need you to report what you know. 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. It can also help us identify issues that can improve corporate culture and performance.

Bapco has implemented a whistleblowing policy to guide the management and oversight of concerns expressed through the EthicsPoint hotline and webform.

Reports are entered directly on the EthicsPoint secure server to prevent any possible breach in security. EthicsPoint makes these reports available only to designated individuals under the direct supervision of Bapco Board Audit and Risk Committee (“BBARC”) which has the overall responsibility of overseeing the reported concerns. Each of these report recipients has had training in keeping these reports in the utmost confidence.

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.

EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your work device 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 device, you have the option of using a device outside the work environment (such as one located at a library, 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.

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.

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 office next to Jan Smith…” or “In my 33 years…”.

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.

There is a section in the report for identifying yourself, if you wish.

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.

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.

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.

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.

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

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 # 80006202, which is available 24 hours a day, 365 days a year.