ETHICSPOINT
FREQUENTLY ASKED QUESTIONS (FAQs)
About EthicsPoint
Reporting – General
Reporting Security & Confidentiality
Tips & Best Practices
About EthicsPoint
Q. Why does KCR contract an independent solution provider for EthicsPoint hotline and web reporting?
A: KCR is committed to creating an open culture and a safe, respectful, and ethical working environment where concerns can be raised at any time without fear of retaliation. There are multiple ways for anyone (including employees, job candidates, external business partners) who is aware of or suspects misconduct, wrongdoing, or violation of the KCR Code of Business Conduct, KCR policies and procedures, or any laws or regulations to report it without any delay.
Q. How do I report my concern via EthicsPoint?
A: If you wish to report a concern via EthicsPoint, you may complete a report on this website, or you may call the NAVEX call center using the EthicsPoint hotline. Both services are available 24 hours a day, seven days a week. NAVEX offers translation services that allow telephone and web reports to be made in multiple languages.
Please note: Available phone numbers vary by country. You can dial these phone numbers free of charge (applies to the listed countries only, others may be charged by your operator). In most cases, phone lines will initially be answered in English. By stating your preferred language, the live operator who answers your call will bring an interpreter on the line if you would prefer to report your concern in a language other than English. It may take a few minutes for an interpreter to join the call so please be patient and do not hang up.
Please note: Although the intake web form may be available in a limited number of languages, you can complete it in a language that is convenient for you. NAVEX is responsible for translating the report into languages contracted by KCR and will forward the translated report to authorized KCR personnel for review and appropriate follow-up.
The EthicsPoint intake questionnaire consists of the same set of questions whether the report is made on the web/mobile form or via telephone hotline supported by NAVEX call center agents. Both reporting options have the same security and confidentiality measures applied to them during transmission.
Over time, KCR will expand the functionality of this site to include the translation of the EthicsPoint main page and intake web form into additional local languages and will increase the number of dedicated phone numbers.
Reporting – General
Q. What types of situations should I report?
A: The EthicsPoint system allows the reporting in good faith of any concern about a situation or event that a person believes may constitute past, present or highly likely future malpractice or wrongdoing in violation of the KCR Code of Business Conduct; and/or any KCR policy/ procedure; and/or any law and regulation or a deliberate attempt to conceal such malpractice or wrongdoing.
To the extent permitted by local laws and regulations, the following concerns may be reported through EthicsPoint (this is not an exhaustive list):
| Auditing, Accounting & Financial Records |
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| Business Integrity |
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| Employee Relations / Human Resources |
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| Environmental Health & Safety |
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| Human Rights |
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| Information Security |
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| Clinical Trial Operations |
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Please note: EthicsPoint should not be used for reporting emergency situations, personal complaints (grievances), adverse events or making false accusations or raising concerns in bad faith.
If you require emergency assistance, contact your local authorities or country’s emergency services.
Whereas personal matters (including grievances related to e.g., interpersonal conflict between KCR employees, terms and conditions of employment, dissatisfaction with the employee's remuneration, dissatisfaction with the employee’s performance feedback or results, etc.) should be raised under relevant KCR HR policies or should be handled through normal line management channels.
If you are unsure whether a matter should be reported, please seek advice by contacting the KCR Compliance Officer directly, or by submitting a question through EthicsPoint ‘Ask a Question’.
* Please be advised that KCR has established a separate reporting channel (managed by the KCR's Data Protection Officer) that is dedicated exclusively to data privacy issues, including reporting data breaches. To expedite communication and analysis of cases in this area, we recommend that you send reports directly to: gdpr@kcrcro.com.
Q. Why should I report what I know? What’s in it for me?
A: Ethical business conduct and integrity are the responsibility of everyone working for and on behalf of KCR. In this way, we work together to build and maintain open communication, an ethical culture, and a healthy and productive environment at KCR. Keep in mind that corporate misconduct can threaten the very existence of an entire company.
Q. Does management really want me to report?
A: They certainly do. In fact, they need you to report. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on KCR and our employees. Also, offering positive input may help identify issues that can improve KCR culture and performance. Please do not assume that someone else will raise this concern. Your reporting may be the only opportunity for the company to learn about the issue and follow-up accordingly. In addition, the KCR Code of Business Conduct requires employees to report suspected misconduct and violation of the company’s Code of Conduct, policies and procedures, and applicable laws and regulations.
Q. Where do these reports go? Who can access them?
A: Reports are entered directly on the EthicsPoint secure server. NAVEX makes these reports available only to authorized KCR recipients who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients handle these reports in the utmost confidence.
Q. Isn’t this system just an example of someone watching over me?
A: No. EthicsPoint is a positive aspect of our overall philosophy that allows us to ensure a safe, secure, and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions via ‘Ask a Question’ option or communicate a concern via the ‘Report a Concern’ option. Effective communication is critical in today’s workplace, and this is a great tool to enhance that communication.
KCR has carefully chosen the best reporting tool to meet its compliance obligations while maintaining a positive reporting environment.
Reporting - Security & Confidentiality
Q. Should I identify myself?
A: As anonymous reporting may be limited/prohibited by local law and/or may impact the possibility of thorough, effective and prompt investigation, KCR encourages anyone who is making a report to provide his/her contact details and as much relevant information as possible, to the extent known by the reporter (including the general nature of the concern, where and when the issue occurred, names of involved/accused/associated people, names of witnesses and any evidence that may support the report).
If you are concerned about possible reprisals for raising a concern, please remember KCR has zero tolerance for any form of retaliation for reporting in good faith.
If you have identified yourself, reasonable efforts will be made to respect your confidentiality. Details of the report (including your identity) will not be disclosed to anyone beyond the authorized personnel who received the report and the KCR Investigation Team responsible for the investigation process (disclosure on a need-to-know basis only) unless disclosure is necessary to conduct a proper investigation, is required during legal proceedings, or by local laws or you have given KCR your explicit written consent.
Q. What information am I asked to provide if I report a concern?
A: You will be asked to provide as much information as possible to the extent known by you, including:
- Personal information if you have chosen to reveal your identity (name, phone number, email address, relationship to KCR (employee, contractor, supplier/vendor, customer, etc.), best time to contact you),
- Details about the concern/issue you are reporting (including the general nature of the concern, where and when the issue occurred, names of involved/accused/associated people, names of witnesses and any evidence that may support the report).
Please note: When answering questions, refrain from speculating, focus on facts. Although reporters are not expected to prove beyond doubt the truth of their allegation, they need to demonstrate that there are reasonable grounds for their allegation. Even if a reporter turns out to be mistaken or unsubstantiated, if it was made based on a reasonable belief and without malicious intent, it can still be considered a good faith report and the reporter will be given protection. However, where it is shown that a malicious, false, vexatious, frivolous, or abusive report was made, a person making such report may be subject to legal and/or disciplinary action according to applicable local law and regulations.
Q. May I report my concern anonymously?
A: The EthicsPoint system protects your anonymity. If you prefer to remain anonymous, you should use the EthicsPoint telephone hotline or web reporting channel. No attempt will be made to determine your identity through electronic means.
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 15 years…”.
Please note: You should also be aware that anonymous reporting in some jurisdictions may be discouraged or prohibited (e.g., Spain). In addition, some local laws may limit the scope of reportable concerns (e.g., in Bulgaria - anonymous reporting related to violations committed more than two years ago are generally not allowed, other anonymous reports are not prohibited but cannot oblige the authorities or the company to act).
Q. How will I be informed of the report’s status and follow-up actions if I have raised my concerns anonymously?
A: After you complete your report, you will be assigned a unique code called a ‘report key’. Write down your report key and password and keep them in a safe place.
After 7-10 business days and periodically thereafter, use your report key and password to check your report for feedback or questions. You should receive the first notification with confirmation of receipt of the report by the KCR Investigation team within 7 calendar days from the date of notification.
It may also be helpful for follow-up contact to provide an email that does not reveal your identity (e.g., creating an additional email address for the purpose of this report). In this way, you will be able to receive notifications from EthicsPoint and continue an anonymous dialogue with the KCR Investigation team via an anonymous dialogue box within EthicsPoint.
Q. What if I lose my Report Key or forget the Password I created?
A: Because of the high level of confidentiality that is maintained for reports, if you lose your report key or password, you will need to file a new report. Please mention in the report that it is related to a previously submitted report or question.
Q. What if I face retaliation?
A: There is zero tolerance for retaliation at KCR. Any form of retaliation against any person who reports a concern in good faith or cooperate in an investigation or assist the reporter in the reporting process will not be accepted at KCR. KCR guarantees protection from retaliation or reprisals, including threats of retaliation and attempts of retaliation, to any person reporting in good faith. If you believe that you or another colleague has been retaliated against for reporting a concern or for participating in an investigation, you should report it immediately using one of the available internal reporting options (including EthicsPoint).
Tips & Best Practices
Q. I am aware of some individuals acting unethically, but it doesn't affect me. Why should I bother reporting it?
A: Our company promotes ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all employees. If you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it.
Q. 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?
A: If you are unsure whether a matter should be reported, please seek advice by contacting the KCR Compliance Officer directly, or by submitting a question through EthicsPoint ‘Ask a Question’. If you would like to schedule a face-to-face meeting with the KCR Compliance Officer to raise a concern directly, please submit a request through the EthicsPoint ‘Ask a Question’ option.
Q. What if my boss or other managers are involved in a violation?
A: The EthicsPoint system and report distribution ensure that implicated parties are not notified or granted access to reports in which they have been named.
Q. What if a member of the KCR Central Investigation Team (KCR CIT) or other Lead Investigators are the ones affected by the reported concern?
A: Any person with actual or potential conflict of interest with the case or the reporter and/or the implicated person will be excluded from the KCR Investigation Team either by the KCR CIT or automatically by NAVEX in EthicsPoint. The KCR CIT members have the role and privileges of the EthicsPoint System Administrators what gives them the ability to view and manage all cases records as well as speak with a reporter(s) (if the reporters have consented or left their identity to be contacted). In the event that the matter relates to a member of the KCR CIT, the reporter or authorized recipients receiving the concern must report the case to the Head of HR & Administration or register it directly through EthicsPoint. In such cases, the report will be automatically assigned to the Head of HR & Administration, who serves as the EthicsPoint System Advocate. Consequently, KCR CIT will not be able to view this particular report or speak with the reporter.
Please note: When providing the details of those involved/accused/associated in reported concern, ensure that all names and functions are up to date and correctly included in the report. Only then, NAVEX will be able to automatically block access to the case for those involved. In the second step - there will be a manual verification of the report by NAVEX, but this option is subject to the risk of human error and omission.
Q. 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?
A: When you file a report at the EthicsPoint web site or through the EthicsPoint call center, you receive a unique number called a “Report Key” 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 KCR Investigation Team. We strongly suggest that you return to the site in the time specified to answer company questions.
Q. Are follow-ups on reports as secure as the first one?
A: All EthicsPoint correspondence is held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.
Q. Can I still file a report if I don’t have access to the Internet?
A: You can file an EthicsPoint report from any computer that can access the Internet. You can file from home, many public locations or the public library. If you don’t have access to or are uncomfortable using a computer, you can call the EthicsPoint hotline, which is available 24 hours a day, 365 days a year.