About EthicsPoint
Reporting – General
Reporting Security & Confidentiality
Tips & Best Practices

About EthicsPoint
What is EthicsPoint?
EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX to assist
management and employees work together in addressing fraud, abuse, and other misconduct inthe workplace, all while cultivating a positive work environment.

Why do we need a system like EthicsPoint?
•We believe that our employees are our most important asset. By creating open channels ofcommunication, we can promote a positive work environment and maximize productivity.

•Publicly traded companies are required by law to have an anonymous reporting vehicle toaddress accounting and auditing fraud directly to the audit committee.

•An effective reporting system will augment our other efforts to foster a culture of integrityand ethical decision-making.

Reporting – General
May I report using either the Internet or the telephone?
Yes. With EthicsPoint, you have the ability to file a confidential, anonymous report via either thetelephone or the Internet.

What type of situations should I report?
The EthicsPoint system is designed for employees to report any violation of our stated Code ofConduct, or other concern you may have.

If I see a violation, shouldn't I just report it to my manager or People & Culture and let them deal withit?
When you observe some behavior that you believe violates our code of conduct, we expect you
to report it. Ideally, you should bring any concerns forward to your direct manager, or othermember of our management team. We recognize, however, that there may be circumstances
when you are not comfortable reporting the issue in this manner. It is for such circumstancesthat we have partnered with EthicsPoint. We would rather you report anonymously than keep
the information to yourself.

Why should I report what I know? What’s in it for me?
We all have the right to work in a positive environment and with that right comes theresponsibility of acting in an ethical manner and letting the appropriate people know if someone
is not acting appropriately. By working together, we can maintain a healthy and productive
environment. Corporate misconduct can threaten the livelihood of an entire company.

Does management really want me to report?
We certainly do. In fact, we need you to report. You know what is going on in our company both good and bad. You may have initial knowledge of an activity that may be cause for concern.
Your reporting can minimize the potential negative impact on the company and our people.
Also, offering positive input may help identify issues that can improve corporate culture andperformance.

Where do these reports go? Who can access them?
Reports are entered directly on the EthicsPoint secure server to prevent any possible breach insecurity. EthicsPoint makes these reports available only to specific individuals within thecompany who are charged with evaluating the report, based on the type of violation andlocation of the incident. Each of these report recipients has had training in keeping these reports
in the utmost confidence.

Isn’t this system just an example of someone watching over me?
The EthicsPoint system concentrates on being a positive aspect of our overall philosophy, andallows us to assure a safe, secure, and ethical workplace. You are encouraged to seek guidanceon ethical dilemmas, provide positive suggestions, or communicate a concern. Effectivecommunication is critical in today’s workplace and this is a great tool to enhance thatcommunication.
We have carefully chosen the best reporting tool to meet our compliance obligations while
maintaining a positive reporting environment.

Reporting Security & Confidentiality
It is my understanding that any report I send from a company computer generates a server log thatshows every web-site that my PC connects with, and won’t this log identify me as a report originator?
EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so noinformation linking your PC to EthicsPoint is available. In fact, EthicsPoint is contractuallycommitted not to pursue a reporter’s identity.
If you feel uncomfortable making a report on your work PC, you have the option of using a PC
outside our work environment (such as one located at an Internet café, at a friend’s house, etc.)
through the EthicsPoint secure website. Many people choose this option, as EthicsPoint’s datashows that fewer than 12% of reports are generated during business hours.

Can I file a report from home and still remain anonymous?
A report from home, a neighbor’s computer, or any Internet portal will remain secure andanonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint
system strips away Internet addresses so that anonymity is totally maintained. Plus, EthicsPointis contractually committed not to pursue a reporter’s identity.

I am concerned that the information I provide EthicsPoint will ultimately reveal my identity. How can
you assure me that will not happen?
The EthicsPoint system is designed to protect your anonymity. However, if you wish to remain
anonymous, you - as a reporting party - need to ensure that the body of the report does notreveal your identity by accident. For example, “From my desk next to Jan Smith…” or “In my 33years…”.

Is the telephone toll-free hot line confidential and anonymous too?
Yes. You will be asked to provide the same information that you would provide in an Internetbased report and an interviewer will type your responses into the EthicsPoint Web site. Thesereports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?
There is a section in the report for identifying yourself, if you wish.

Tips & Best Practices
I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should
I bother reporting it?
Our company chooses to promote ethical behavior. All unethical conduct, at any level,ultimately hurts the company and all employees, including you. You only have to consider what
happened in recent corporate scandals to see the disastrous effects that a seemingly harmlesslapse in ethics can have on an otherwise healthy company. So if you know of any incidents of
misconduct or ethical violations, consider it your duty to yourself and your coworkers to reportit.

I am not sure if what I have observed or heard is a violation of company policy, or involves unethicalconduct, but it just does not look right to me. What should I do?
File a report. EthicsPoint can help you prepare and file your report so it can be properly
understood. We'd rather you report a situation that turns out to be harmless than let possible
unethical behavior go unchecked because you weren't sure.

What if my boss or other managers are involved in a violation? Won’t they get the report and start acover-up?
The EthicsPoint system and report distribution are designed so that implicated parties are notnotified or granted access to reports in which they have been named.

What if I remember something important about the incident after I file the report? Or what if thecompany has further questions for me concerning my report?
When you file a report at the EthicsPoint Web site or through the EthicsPoint Call Center, youreceive a unique user name and are asked to choose a password. You can return to theEthicsPoint system again either by Internet or telephone and access the original report to add
more detail or answer questions posed by a company representative and add further
information that will help resolve open issues. We strongly suggest that you return to the site in
the time specified to answer company questions. You and the company now have entered into
an “anonymous dialogue,” where situations are not only identified, but can also be resolved, nomatter how complex.

Are these follow-ups on reports as secure as the first one?
All EthicsPoint correspondences are held in the same strict confidence as the initial report,continuing under the umbrella of anonymity.

Can I still file a report if I don’t have access to the Internet?
You can file an EthicsPoint report from any computer that can access the Internet. You can filefrom home. Many public locations, including the public library, have Internet computers. If you
don’t have access to or are uncomfortable using a computer, you can call the EthicsPoint tollfree hotline, which is available 24 hours a day, 365 days a year.