The Speak Up Line is a web-based site supported by the third-party vendor, Ethico. It is a comprehensive and confidential reporting tool that enables all our personnel to address fraud, abuse, and other misconduct in our environment and to promote a healthy and safe experience for everyone.

Yes. Ethico’s call centers accept reports for our organization via telephone or the web form, 24 hours a day, seven days a week.

Yes! As a reporter, you are NOT required to identify yourself, whether submitting your report by webform or by telephone. Providing your name and/or contact information is entirely optional. At the completion of the reporting process, you will be provided a case number that will allow you to follow-up on your case at a later time.

You can raise concerns about potential violations of the company’s global policies, our Code of Conduct, the law or regulations. Some examples are concerns regarding financial wrongdoing, harassment, discrimination or other issues in the workplace, data privacy and information security, third party vendor management issues, misuse of company assets, fraud, human rights, unfair business practices, conflicts of interest, and more. Reporters are protected from retaliation for concerns raised in Good Faith (believed to be true).

Additional Examples:

• Specific incidents of unacceptable or disruptive colleague behaviors (physical or verbal)
• Employee relations matters (hiring practices, retaliation, discrimination, harassment, workplace conflicts)
• Unsafe work environment (safety rules not followed, broken equipment, staff afraid to stop the line, etc.)
• Documenting or billing for services not provided
• Using position or company resources for personal gain, non-work related reasons
• Ongoing, previously reported concerns that require an independent review
  
• Questions or seek guidance on matters when it is uncomfortable speaking with your manager or member of management

The Case Manager must receive specific details concerning the matter in order to facilitate a thorough review. Providing partial or incomplete information may result in case closure due to insufficient information. Information needed to complete a thorough review may include:

• First/last name of person(s) or organization(s) engaged in alleged wrongdoing
• Description of the event, location, and date/time of when event occurred
• Specific details or synopsis of the concern(s) being raised
• First/last names of witnesses to the event or others who may have knowledge of the concern(s) being raised
• How the event was discovered if the reporter was not a participant or directly involved
• Supporting documentation if available, including policies, memoranda, emails, text messages, etc.

Yes. When reporting online, you can upload documents, related evidence, photos, etc., as attachments. If you report by telephone, Ethico’s hotline agents may be able to provide you with an email address so you can forward supporting documentation.

As our organization continues to achieve standards of excellence, we must be diligent and maintain high standards of integrity. In the best interest of our organization, you have an obligation to report unsafe practices, unethical behavior or violations pertaining to the Code, policy or procedure, or applicable law or regulation.

When someone’s actions violate our Code, our policies or procedures, or applicable laws or regulations, it can harm not only the involved parties, but our whole organization. If a law is violated, the result could be civil or criminal action against our organization and/or the person(s) responsible.

We take any potential violation seriously. Reports of potential misconduct are reviewed carefully and steps are taken to correct the situation, including disciplinary action when appropriate.

Reports made online, or through Ethico’s call centers, are maintained on Ethico’s secure servers. A limited number of designated employees at our organization have access to view and investigation reports for our organization. Ethico’s employees and

our organization’s personnel are specially trained to handle complex and sensitive matters in a confidential manner.

Each allegation reported is unique, so the estimated time of completion depends on many factors, such as the complexity of the issue, the number of people involved, the nature and extent of documents or other evidence involved, and the urgency of the matter.

As a reporter, you may check on the status of your case at any time, either by telephone or online.

Reporters following up on a case online will be required to provide the original case number and a passcode. For verification purposes, reporters following up by telephone will be required to verify key report content along with providing their original report number.

Confidentiality means thatCase Managers will not disclose information to individuals outside of the reasonable “need to know” standard. This includes information received, used, maintained or accessed during the course of normal duties, such as case reviews.

Anonymity means that personnel may report any concern through the reporting channels without disclosing their identity. Reports made in good faith will be taken and reviewed without an attempt to identify the reporter.

Be advised that:

• There are circumstances in which confidentiality and anonymity may not be maintained, including but not limited to disclosures pursuant to a subpoena or court order, a lawful discovery request
• Anonymity applies to an individual’s identity.
• Confidentiality applies to information received, used, maintained or accessed.
• Reporters may choose to release their identity during or after a completed investigation.
• Information shared outside of the Speak Up Line case review process is not protected.  Meaning if you talk about it with your co-workers (excluding investigators), we can’t guarantee your anonymity 
• Information shared through the reporting channels may lead to indirect identification of a reporter given the specific details provided.  However, investigators will protect the identity of the reporter to the fullest extent possible.