About EthicsPoint

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX that enables all parties to work together to address fraud, abuse, and other misconduct in the workplace as well as along the supply chain whilst 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?

The EthicsPoint for Rakuten Symphony suppliers enables you to file a confidential, anonymous report via either the Internet or the mobile phone application. [We currently do not support telephone hotline communications.]

What types of situations should I report?

The EthicsPoint system allows employees to report any violation of the Rakuten Symphony stated Code of Conduct, Ethical standards for purchasing and procurement or other concerns regarding potentially unjust behavior occurring in the supply chain.

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 Rakuten Symphony Code of Conduct or Ethical standards for purchasing and procurement, we expect you to report it. It is for such circumstances that we have partnered with NAVEX. We prefer you report your concerns to keep both parties safe, rather than keep the information to yourself.

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. Misconduct by either party can threaten the very existence of our business relationship and negatively affect all stakeholders.

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 who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports in the utmost confidence.

Isn’t this system just 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 and business relationship. 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.

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. It seems that many people choose this option, as NAVEX data shows that fewer 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 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, 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 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.

What if I want to be identified with my report?

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?

Rakuten Symphony promotes ethical behavior. All unethical conduct, at any level, ultimately hurts all stakeholders, 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 ethical violations, consider it your duty to yourself, your coworkers, and your business partners to report it.

I am not sure if what I have observed or heard is a violation of Rakuten Symphony’s Code of Conduct or Ethical standards for purchasing and procurement, 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.

What if my boss, managers, or business partners 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 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 if there are further questions for me concerning my report?

When you file a report at the EthicsPoint Web site or through the mobile application, you receive a unique, randomized number called a “Report Key” and are asked to choose a password. You can return to the EthicsPoint system again either by Internet or mobile application and access the original report to add more details or answer questions posed by relevant stakeholders.

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

All EthicsPoint correspondences are held in the same strict 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. Mention in the new report that it is related to a report or question you previously submitted.