MyComplianceReport is a web-based portal supported by the third-party vendor, ComplianceLine. It is a comprehensive and confidential reporting tool that enables all Ethico Personnel to address fraud, abuse, and other misconduct in our environment and to promote a healthy and safe experience for everyone.

Yes. The (ComplianceLine) Integrity Line accepts reports via telephone (1-877-876-5463 (US) & 800-020-4627 (MX)) or the web form.

The Integrity Line is an all-inclusive term and refers to the MyComplianceReport web-based portal as well as the toll-free telephone number.

Yes. The Integrity Line does not attempt to identify reporters, whether submitting telephonically or electronically. Reporters have the option to remain anonymous or provide their name and other contact information. Reporters are provided a Report Key that allows for anonymous communication with a member of the Compliance and Ethics Department.

Any questions or concerns regarding actual or potential violations of applicable law, regulation, policy or procedure, or the Code of Conduct (Code) should be reported. Reporters are protected from retaliation for concerns raised in Good Faith (believed to be true).

Examples:

• Suspected violations of laws, regulations, company policies, or the code of conduct
• Corrupt business practices, such as bribery or kickbacks
• Unauthorized disclosure of confidential company information
• Misappropriation or misuse of company property or assets
• Ongoing, previously reported concerns that require an independent review
• Questions or seek guidance on matters when it is uncomfortable speaking with an Office of Talent Management (OTM) Business Partner or member of management

The Compliance and Ethics Department 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.

Reports made through the Integrity Line are maintained on the Ethico secure server. A limited number of employees in the Compliance and Ethics Departments can access these reports. These employees are specially trained to handle complex and sensitive matters in a confidential manner.

Each allegation reported through the Integrity Line 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. Reporters may use the Report Key to check on the status of a review or communicate with the lead investigator.

Reporters are provided a Report Key that allows for anonymous communication with the assigned investigator or a member or the Compliance and Ethics Department. The Report Key is a form of a report identification number that allows the reporter to check on the status of a case review or communicate with the lead investigator. On the Integrity Line homepage, click ‘Follow-up’ to ask questions, provide updates or inquire about the status of the review.

Confidentiality means that members of the Compliance and Ethics Departments 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.