Our business is governed by complex, demanding, and ever-changing
laws, rules, and regulations. We recognize that the application
of these laws, rules, and regulations can create uncertainty
for employees in some situations. Our Company is committed
to providing each employee with the resources and training
needed to make ethical and legal decisions while performing
his or her job.
Questions and concerns about the proper way to handle different
situations may, and often do, arise. Open discussions of
issues and concerns by all employees without any fear of
retaliation are essential to the success of the Compliance
Program and our Company. The Compliance Program gives us
the tools to help resolve concerns or questions an employee
may have about business ethics and integrity. We must raise
questions when we have doubts about whether an action or
situation may be improper.
We all have the responsibility to engage in appropriate
business conduct. In addition, we must report any activity
which we, in good faith, believe may be a violation of any
applicable laws, regulations, policies or the Code of Business
Ethics and Conduct. The Company has an absolute policy against
any retaliation for bringing forward a good faith concern.
Any person who violates this policy will be subject to disciplinary
action up to and including termination.
We are always encouraged to talk to our Supervisor first
about any questions or concerns we may have. However, there
are alternative resources available, including the Corporate
Integrity HOTLINE, as outlined in the following steps.
Step 1
When in doubt, ask and keep asking until you get an answer
that makes sense.
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Is any law or regulation being violated?
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Is the action consistent with our Company
values, our Code of Business Ethics and Conduct and
our Company policies?
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If you know it is wrong, don’t
do it!
Step 2
Discuss the issue with your immediate Supervisor who knows
you and the issues in your workplace. Give your Supervisor
a chance to solve the problem. If you still have concerns
after talking with your Supervisor or if you are not comfortable
discussing the issue with your Supervisor, go to the next
step.
Step 3
Discuss the issue with a higher level Supervisor. If you
still have concerns after your discussion, or if you are
not comfortable discussing this issue with a higher level
Supervisor, go to the next step.
Step 4
Discuss the issue with another Corporate Resource or the
Compliance Officer. The most current list of Corporate
Resources can be found on the Compliance home page on
the Company’s intranet. If you are not comfortable
taking this step, go to the next step.
Step 5
Call our Corporate Integrity HOTLINE at 1-800-838-2552.
Your call can be anonymous; you are not required to provide
your name. For more information, please see the section
of the Code titled Corporate Integrity Hotline.
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