About Reporting

• All employees are held accountable for their actions and are required to report unethical or unlawful activities. Managers are ultimately responsible for ensuring that the employees they supervise are knowledgeable about and in compliance with the contents of this Employee Handbook. Any employee who violates any of the codes or policies in this Employee Handbook, or who is aware of, but fails to report any such violation or any other unlawful or unethical business behavior, is subject to disciplinary action, including termination of employment and/or legal action.
• Reasonable judgment must be exercised to avoid baseless allegations. An employee who intentionally files a false report of wrongdoing will be subject to discipline up to and including termination. Employees who file reports in good faith will not be subject to discipline.
• Retaliation for filing a report is prohibited. Any employee who has reported what he/she believes to be illegal or unethical activity or a violation of the codes or policies in this Employee Handbook, and who believes he/she is being retaliated against must contact the Corporate Compliance Officer immediately. The right of an employee for protection against retaliation does not include immunity for any personal wrongdoing that is alleged or discovered in the course of the investigation.
• Anonymous reports will be accepted, but those making a report are encouraged to identify themselves in case more information is needed during the investigation. To the extent possible, the confidentiality of the person filing the report will be maintained. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defense.
• A person making a report is not responsible for investigating the activity or for determining fault or corrective measures. Appropriate management officials are charged with these responsibilities.