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Section 7: Prompt Internal Reporting of Your Concerns
Your Duty to Speak Up
No company can live up to its commitment to act with integrity if we, as individuals, do not speak up when we should. That is why, in addition to knowing the legal and ethical responsibilities that apply to your job, you should speak up if:
- you are ever unsure about the proper course of action and need advice
- you believe that someone acting on behalf of the Company is doing--or may be about to do-- something that violates the law or the Company's Code of Conduct
Whom Should I Contact For Help?
If you have a concern about a legal or business conduct issue, you have options. The most important thing is that you use one of these options to ask the question or raise the concern.
Your supervisor is usually a good place to start with a business conduct issue. You may also get help or advice from the Company's Compliance Officer.
The Integrity WebLine(sm)
If you ever feel unsure about where to go, or are uncomfortable using one of the other resources identified in the Code, we have an additional resource that can help: the Integrity WebLineSM service. You can access the Integrity WebLine service the same way you access the Company's online Code of Conduct training.
The sole purpose of the Integrity WebLine service is to answer questions and respond to concerns about compliance, integrity and the policies described in this Code of Conduct. You can use the Integrity WebLine service anonymously 24 hours a day, seven days a week.
Remember, too, that if you wish to raise concerns about accounting or auditing matters on an anonymous basis, you can use the Integrity WebLine service. Confidentiality will be maintained to the extent consistent with the law, our need to investigate, and our Company's commitment to cooperate with law enforcement. Any such concerns in this area will be transmitted directly to the audit committee, which is composed of independent members of the Company's board of directors
Retaliation Will Not Be Tolerated
Any employee who, in good faith, seeks advice, raises a concern, or reports misconduct is following this Code of Conduct--and doing the right thing. The Company will not allow retaliation against that person. Individuals engaging in retaliatory conduct will be subject to disciplinary action, which may include termination. If you suspect that you or someone you know has been retaliated against for raising a compliance or integrity issue, immediately contact the Integrity WebLine service or the Compliance Officer.
We take claims of retaliation seriously. Retaliation against anyone reporting a violation in good faith is strictly prohibited and subject to discipline.
We All Must Follow the Code of Conduct and the Guide to Governmental Laws
All directors, officers, employees, and others who perform work for the Company will be held accountable for complying with the law, this Code of Conduct, and the Guide to Governmental Laws, Rules, and Regulations.
Enforcement: Discipline Will be Imposed for Violations
Violations of the law, this Code, or the Guide are subject to discipline, up to and including termination of employment by the Company. Illegal action will be dealt with swiftly and the violators reported to the authorities, as appropriate. Enforcement will be prompt and consistent, applying appropriate standards and processes as determined by the Compliance Officer.
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Q: What happens if I violate the Code of Conduct "accidentally"?
A: Each employee is required to be familiar with the Code of Conduct and to understand what the Code requires at work. In addition, each employee should be familiar with those portions of the Guide to Governmental Laws that affect the employee's job.
Violating the Code of Conduct, the Guide or the law will result in disciplinary action, termination of employment--and, in some cases, even criminal prosecution.
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