Frequently Asked Questions
- SPEAK UP PROGRAM, WHAT TO REPORT AND HOW TO REPORT
- Suspected or known bribery / corruption (Benefits offered or given to a customer to encourage or reward the purchase of products, bribery or attempted bribery of government officials, customers or others, giving any kickback to a customer or receiving any kickback from a Puma supplier/vendor of products or services).
- Suspected or known non-compliance with product quality requirements.
- Suspected or known false accounting or recording of information (Inaccurate creation, reporting or falsification of company business and financial records or regulatory submissions; Improper booking/accounting of sales revenue or expenses; Intentional misstatement of accounting records).
- Suspected or known conflicts of interest (actual, apparent or potential) with the aim of financial gain or misuse of Company assets.
- Suspected or known insider trading.
- Suspected or known money laundering.
- Suspected or known breaches of trade restrictions, anti-boycott laws, export controls or sanctions.
- Suspected or known anti-competitive behavior such as exchange of pricing or other proprietary information with competitors.
- Suspected or known unsafe work practices.
- Suspected or known dissemination of slanderous, offensive or deliberately false or misleading communications.
- Suspected or known unauthorized political activity and payments.
- Suspected or known breach of law, regulation or court order.
- Suspected or known theft or fraud, either from Puma Energy or by a Puma employee, contractor or third-party agent.
- Suspected or known workplace violence.
- Suspected or known harassment, bullying, retaliation, victimization or discrimination.
- Suspected or known breaches of IT system/policy or data privacy laws.
- Suspected or known failure to comply with applicable policies and procedures or internal controls (e.g. gifts and entertainment policy, Puma Code of Business Conduct).
- Other suspected or known incidents where there is a potential financial, reputational or regulatory risk that could be significant to Puma Energy.
- Suspected or known retaliation against any employee reporting a concern.
- Suspected or known issues relating to intellectual property rights.
- Other types of suspected or known unethical behaviors.
- Puma Compliance Representative
- Puma Legal Representative
- The Puma Energy Speak Up line either via the toll-free telephone line or via the website or using Mobile intake form.
- NO RETALIATION
- ABOUT PUMA ENERGY SPEAK UP HOTLINE
- provide telephone and web-based options through which people can report a concern about the business conduct of a Philips employee, customer, supplier or other stakeholder.
- protect the identity of reporters who wish to remain anonymous.
- provide language support for people who wish to report an incident by phone in their local language.
- send information about the concern to Philips so that it can be followed up effectively.
- enable Philips to communicate with an anonymous reporter by acting as an intermediary to relay follow-up questions and answers as well as information about the resolution of the case.
- AFTER A REPORT IS SUBMITTED
- Never discourage others from reporting a problem.
- Report concerns in good faith – never knowingly make a false report.
- Give due regard to protecting the rights and concerns of anyone accused of misconduct.
- Be truthful, candid, and cooperative in any investigations.
- Never retaliate against an employee who makes a report.
- SPEAK UP
Q: What do you mean by “Speak Up”?
A: Puma Energy would like you to speak up when you have any legal, compliance, policy, or business-ethics questions or if you have a concern about any known or suspected wrongdoing or misconduct.
There are several channels that you can use to ask questions, raise concerns or report known or suspected wrongdoing or misconduct. These include your line manager, one-over-one manager, Human Resources Representative, Puma Legal team, Compliance Representative and the Puma Energy Speak Up line.
The Puma Energy’s Speak Up line consists of a website and a toll-free telephone line through which — if desired and permitted under local law — you can report anonymously any concern about any known or suspected wrongdoing or misconduct relating to the violation of Puma Energy’s Business Code of Conduct or Policies or local laws. The toll-free telephone line is available 24 hours a day / 7 days a week / 365 days a year.
Q: What impact does “speak up” really have?
A: Speaking up allows you to obtain guidance when you are unsure what to do in a particular situation. By speaking up to raise concerns, you help protect Puma Energy and our colleagues from potential losses, legal actions, injuries or reputational damage.
Q: When should I speak up?
A: Speak up to ask questions if you are unsure about the proper course of action and need advice about an ethics or compliance concern.
Speak up to raise concerns if you believe that someone acting on behalf of Puma Energy has done, is doing, or may be about to do something that violates the law, our Code of Business Conduct and Ethics or Puma Policies and procedures.
Speak up to self-report if you believe that you yourself may have been involved in misconduct when doing something on behalf of Puma Energy.
Q: What if I am the one that may have been involved in conduct that violates the law or company policy?
A: In many cases, standards are violated due to ignorance or mistake, not deliberate and premeditated misconduct.
If you believe that you have been personally involved in an instance of non-compliance, you are still encouraged to speak up and get it resolved.
All allegations will be reviewed and appropriately addressed; we look at the facts of each incident to ensure fair treatment, including the reasons for a violation, good faith of the people involved, and timeliness of corrective action.
Q: What if my supervisor tells me to “keep quiet” about a question or concern I’ve raised – or not to cooperate with a compliance investigation?
A: If you think that you are being discouraged from reporting a potential violation of the law or company policy, you should report both the original concern and the fact that you have been told to “keep quiet.”
Q: How seriously will I be taken when I speak up to raise concerns?
A: We take seriously all questions asked and concerns raised. We respond to questions as soon as practically possible. We evaluate reports of concerns and conduct investigations when appropriate.
Q: What are some examples of concerns that I should raise?
A: Here are a few examples of the types of issues you should report:
Q: How do I speak up?
A: You have a number of options. Typically, the best person to ask questions to and raise concerns with is your line manager, another member of management within your business unit/geography or your local Human Resources representative, as they are likely to be closest to the issue and may be able to provide a quick response.
If you are uncomfortable reporting an issue within your business unit, or local reporting is not appropriate because of the nature of the issue or people involved, other options include:
Q: What if my manager or other managers are involved in a concern?
A: You can raise this concern through the Speak Up line anonymously.
Q: Will speaking up have an adverse effect on my career prospects?
A: No. Puma Energy will not tolerate retaliation against any person who raises a concern, in good faith,– regardless of that person’s stature within the company or the stature of the person about whom a concern is reported.
If a reporter informs Puma Energy about retaliation, Puma Energy takes this seriously and investigates. Puma Energy will discipline anyone who engages in retaliation
Q: Who oversees running Puma Energy’s Speak Up?
A: Puma Energy’s Speak Up is run by NAVEX, a third-party supplier that specializes in ethics & compliance programs. This set-up ensures maximum confidentiality, as reports are stored on a database outside the Puma Energy environment. Furthermore, in order to ensure anonymity and confidentiality, the call center does not use any recording devices or simulated electronic voice greetings. Incoming calls are not subject to Caller ID screening.
NAVEX's principal responsibilities are to:
It is specifically not NAVEX's role to address the concern itself.
Q: What if I want to remain anonymous?
A: All calls and electronic web reports to Puma’s Speak Up line provides the option to remain anonymous, where allowed by local law.
However, if you chose to be anonymous, please provide complete details so it can support in a comprehensive assessment of the complaint, otherwise it becomes challenging for Puma Energy to action.
Q: Will my call be recorded by an answering machine? Will my voice be identified?
A: No. Puma Energy Speak Up phone lines will have available a number of trained communications specialists who will conduct all interviews and prepare all reports. The call center does not utilize any recording devices or simulated electronic voice greetings. Incoming calls are not subject to Caller ID screening.
Q: Can my phone number be identified?
A: Incoming calls are identified only as originating from a specific country. This feature enables the communications specialists at the call center in question to answer the call with the appropriate greeting in your local language and to access the appropriate electronic reporting intake form. There are no caller identification systems connected to the call center telephone lines and your call will not be screened.
Q: Can I be identified through my IP address?
A: The Puma Energy hotline is managed by NAVEX. NAVEX does not generate or maintain any internal connection logs with IP addresses. There is therefore no information available to link your PC to the use of the Puma Energy’s Speak Up Line.
If you feel uncomfortable reporting an incident from your work PC, you can use a PC outside the work environment (e.g. in an internet café, at a friend's house, etc.) to report an incident via Puma Energy’s Speak Up secure website or you can use the mobile access.
Furthermore, NAVEX is contractually obliged not to try and identify a reporter.
Q: Is the toll-free telephone hotline confidential too?
A: 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 directly into the Puma Energy’s Complaints database. The same level of security and confidentiality will apply if you choose to report an incident in this way.
Q: How can I follow up with a report that I have submitted?
A: Prior to the end of an interview or when you report an incident online you will be given a unique code number for identification, callback and feedback purposes (report key/password).
All reporters are encouraged to call back or submit a follow-up report if they have additional information about the incident they have reported, if they observe any other incidents, or if they wish to check on the progress or the resolution of their complaint. This report key further guarantees the anonymity of callers. Make sure you keep this key safe ‒ it is the only way you can check on the progress of the investigation relating to your complaint.
Q: What should I do if I lose my report key or password?
A: Because of the confidentiality level maintained for reports, the process requires you to file a new report if you lose your report key or password. You can mention in the latest report that this matter relates to another report you filed earlier.
Q: What if someone makes an unfounded anonymous call against me?
A: All complaints that are submitted via Puma Energy’s Speak Up line are reviewed and investigated with due care to establish whether the complaint is substantiated. Action will only be taken if an allegation proves to be justified; you do not need to worry about being personally at risk if the allegations are unfounded.
Q: What happens when I make a report?
A: We evaluate reports of concerns and conduct investigations of actual or suspected wrongdoing or misconduct as appropriate. Our response to a particular reported concern depends on the circumstances.
Q: Will I be required to provide evidence to support my claim?
A: You do not need supporting evidence to raise a concern. However, please provide information in as much detail as possible. Details should include the who, what, when, where, why, and how concerning the allegation(s) raised. If possible, you can attach evidence such as documentation or emails that help substantiate your claim(s). Reports that do not reasonably satisfy conditions of completeness may not be reviewed or investigated further.
Q: What will management do about my concerns?
A: Each case is unique, but we use a consistent process. We may determine that we do not need to act, or, at the other end of the spectrum, we may need to self-report to the government.
For example, management may determine to implement remedial measures or take disciplinary action against employees who have violated the law or company policy, including our Code of Business Conduct.
Q: Will I be told about the details of an investigation or its outcome?
A: In most cases, you will be told whether your reported issue was investigated and whether it was completed. However, there are legal and other restrictions on what information Puma Energy is allowed to provide.
If you raised an anonymous concern through the Speak Up line, you would get a response on the system, using the report key/password issued to you when you submitted your complaint.
Q: Where happens when I ask a question?
A: When you ask a question, the system will direct it to the respective Puma Energy compliance team, who will respond to you through the hotline. If you asked your question anonymously you can use the report key/password to access the response.
Q: What else is expected of me?
A:
Thank You