About EthicsPoint

What is EthicsPoint?

Your Voice uses EthicsPoint as one of the channels for comprehensive and confidential reporting created by NAVEX. The channel helps management and employees work together to address fraud, abuse, and other misconduct while cultivating a positive work environment.

Why do we need a system like EthicsPoint?

• We highly value our employees and recognise them as our most critical asset. We strongly believe that open communication channels are essential to promoting a positive work environment and maximizing productivity.
• We also acknowledge that every Company faces the risk of internal issues and wrongdoing. Therefore, we have established a Hotline that serves as a platform for employees and stakeholders to report suspected or actual wrongdoing. All calls made to the Hotline will be directed to an independent third party to ensure transparency and confidentiality.
• We believe that an effective reporting system will enhance our efforts to promote a culture of integrity and ethical decision-making. Our commitment to ethics, compliance, and privacy drives us to maintain an environment where our employees and stakeholders can raise concerns without fear of retaliation or discrimination.

Reporting – General

May I report using either the Internet or the telephone?

Yes. With Your Voice, you can file a confidential report via the telephone or the Internet. You can also choose to remain anonymous.

What types of situations should I report?

As part of our ethics, compliance, and privacy commitments, we encourage you to speak up if you have any concerns or queries regarding breaches of our Code of Conduct, illegal activities, or unethical or improper behaviour. Your Voice is a platform that you can use to report such issues. However, please note that Your Voice is not a substitute for our grievance procedures. If you have personal issues such as salary scale, performance ratings, or promotion processes, you should follow the Company's grievance procedures unless there is illegal, non-compliant, unethical, or improper conduct involved. Additionally, while you can use Your Voice to ask compliance-related questions, it is usually better to direct such queries to your supervisor, manager, or the EKFC Compliance (ECP) team.

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

We encourage you to raise any concerns or issues you may have with your direct supervisor, manager, or other members of our management team. However, we understand that there may be situations where you may not feel comfortable reporting the matter in this way.

To address such concerns and ensure that you have a safe and secure avenue to report any issues anonymously, we have established Your Voice. We strongly urge you to utilise this platform if you have any concerns that you feel uncomfortable sharing with your supervisor or that your concerns have not been addressed appropriately. We believe it is better to report anonymously than to keep important information to yourself.

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

We are committed to upholding ethical standards and complying with our Code of Conduct. If you witness any behaviour that raises concerns or may constitute a violation of our Code of Conduct, please report it immediately. This will enable us to address and rectify the issue before it significantly threatens health, safety, or Company's reputation. By working collaboratively, we can foster a positive and productive work environment.

Does management really want me to report?

We encourage and value your input as part of our ethics and compliance commitments. We rely on you to report any positive or negative information that may affect our Company and its people. Your reporting can help us address concerns early and prevent potential negative consequences. Additionally, sharing positive feedback can assist us in identifying areas for improvement and enhancing our corporate culture and performance.

Where do these reports go? Who can access them?

To ensure the security of reported concerns, we use the EthicsPoint secure server, which prevents potential breaches in confidentiality. Access to these reports is restricted to the Company’s Ethics, Compliance and Privacy (ECP) department and designated individuals within the Company who are responsible for investigating the reported violations based on their type and location. We uphold strict confidentiality standards and only share information on a "need to know" basis to address the reported concerns or as required by law.

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

We are committed to fostering a safe, secure, and ethical workplace. As part of this commitment, we utilise Your Voice, a reporting tool allowing employees to seek guidance on ethical dilemmas, provide positive suggestions, or report concerns. We recognise that effective communication is crucial in today's workplace, and Your Voice through EthicsPoint is a valuable tool for enhancing that communication.

We want to encourage all employees to use this tool to raise any concerns or suggestions they may have so that we can continue to improve our workplace and operations

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?

EthicsPoint does not produce or retain internal connection logs containing IP addresses. Therefore, no information that connects your PC to Your Voice/EthicsPoint is available. Furthermore, EthicsPoint is obligated by contract not to seek the identity of a reporter. If you feel uneasy about filing a report using your work PC, you can utilise a PC outside of work, such as at an internet cafe or a friend's residence. Many individuals prefer this option, as more than 88% of reports submitted to EthicsPoint are done outside business hours.

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

A report submitted through a home computer, a neighbour’s device, or an internet portal will be kept secure and anonymous. Internet portals do not disclose the visitor's identity by their screen name, and the Your Voice/EthicsPoint system removes internet addresses to maintain anonymity. Furthermore, EthicsPoint has a contractual obligation to refrain from revealing the identity of the person who submits the report.

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

The Your Voice/EthicsPoint system aims to safeguard your anonymity. However, if you intend to remain anonymous while reporting, you must ensure that your identity is not inadvertently disclosed in the report's content. For instance, avoid mentioning specific personal details such as your location or tenure, such as "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 Your Voice/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?

A section in the report allows you to identify yourself if you choose. We highly recommend that you identify yourself, as it facilitates the investigation process and enables us to follow up with you directly.

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 behaviour. 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 of a lapse in ethics on an otherwise healthy Company. If you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report them.

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?

Please discuss any concerns with your supervisor, management, or the ECP member. If you remain unsatisfied with their response or are unwilling to engage with them, please file a report. You should report a situation that ultimately proves to be harmless rather than allowing potential unethical conduct to go unaddressed due to uncertainty.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

Parties mentioned or involved in reports will not be informed or provided access to the reports they are 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 submit a Your Voice report through the internet or telephone, you will be given a distinct user name and prompted to select a password. You may revisit Your Voice using the internet or telephone to amend the original report by adding more information or responding to queries from a Company representative. It is highly recommended that you return to the platform within the specified timeframe to answer any questions posed by the Company. This establishes an "anonymous dialogue" between you and the Company, enabling the identification and resolution of complex situations.

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

All follow-up communications conducted via Your Voice will be treated with the same level of confidentiality as the initial report. If you have opted for anonymity, your identity will remain undisclosed.

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

To ensure that security and confidentiality are 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?

Certainly, you can gain Internet access through a friend's computer or device or a public location like an Internet cafe or public library. However, it is important to obtain their permission beforehand. If you do not have access or feel uneasy about using the Internet, contact the Your Voice toll-free report line. This service is available 24/7 throughout the year.