Code of Conduct: Addressing Integrity Concerns

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 ensuring that each employee is provided the support and training that are necessary to perform his or her job in an ethical and legal manner.  

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 Corporate Compliance Program and our Company.  The Corporate Compliance Program gives us the tools to help resolve any 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.

  • Is any law or regulation being violated?
  • Is the action consistent with our Company values, our Code of Business Ethics and Conduct and our Company policies?
  • 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 Company’s Compliance Officer. The most current list of Corporate Resources can be found on the Corporate 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  page ___.