EthicsLink Q&A

Your EthicsLink Questions Answered.

Q. What is EthicsLink®?

EthicsLink is a comprehensive and anonymous reporting tool to assist management and employees to work together to address suspected financial misconduct, including accounting and auditing matters, contract issues, fraud and securities violations.

Q. Why do we need a system like EthicsLink?

There are several reasons why we need a reporting tool:

• As a third party provider, EthicsLink can ensure that you can report financial problems anonymously and confidentially.
• By creating open, confidential and anonymous channels of communication, we can promote a positive work environment and maximize productivity.
• Reporting "hot-lines" have proven to be an effective tool in reducing losses due to fraud and abuse.
• As a publicly-traded company, Company is required by law and the NYSE to have an anonymous and confidential reporting system to address accounting and auditing misconduct.

Q. Does management really want me to report?

Yes we do. In fact, we need and require you to report. You know what is going on in our company - both good and bad. In many cases you may have initial knowledge of some financial 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 can often help identify issues with which we were unaware.

Q. Why should I report what I know? What's in it for me?

We all have the right to work in a positive environment. But with that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting appropriately. Only by working together can we ensure that we maintain a healthy, positive and productive environment.

Q. What type of situations should I report?

EthicsLink is a communications tool providing an avenue for sharing information about financial and related financial ethical violations, including: accounting and auditing matters, falsification of contracts, reports or records, fraud, and securities violations.

You should continue to use Company's toll-free ethics hotline (XXX-XXX-XXXX) to report other types of ethical violations or other types of misconduct (e.g., theft, sexual harassment, discrimination, collusion, reports on safety, facility security issues, and environmental concerns, as well as positive suggestions and questions regarding rules or policy clarification.)

Q. If I see a violation, shouldn't I just report it to my manager, to security, or to human resources and let them deal with it?

You certainly can, but EthicsLink is a way to report the financial problems anonymously and confidentially, using the Internet (or EthicsLink's toll-free number). Also, EthicsLink ensures that your report gets to the appropriate people. That may or may not happen if you simply report something to your manager, especially when dealing with issues not under his/her control. More importantly, reports can be filed anonymously and all report information is secure and held in the strictest confidence.

Q. It is my understanding that any email I send from a company computer can be read, tracked or recovered. Won't our technology team be able to identify me as the report originator?

Absolutely not. EthicsLink uses a number of security and confidentiality techniques to ensure that your identity is kept confidential whether you are reporting from a company computer or an outside system.

• Messages are encrypted so they are protected from unauthorized access and viewing.
• EthicsLink's system prevents reporter identification should a report be sent from a workstation on our network.
• EthicsLink is accessed through a web portal and screen names are never captured (no cookies), further protecting your identity.
• Reports are only sent to specific members of management and the report delivery system is designed to insure reports are never shared inappropriately or intercepted.

Q. I am concerned that the information I provide EthicsLink will ultimately reveal my identity. How can you assure me that will not happen?

The EthicsLink system is designed to protect your anonymity. However, you as a reporting party need to ensure that the body of the report does not reveal your identity by accident, for example, "From my cube next to Jan Smith-" "In my 33 years-".

Q. I am aware of some individuals involved with unethical financial conduct, but it doesn't affect me. Why should I become involved?

Through our Code of Conduct you are required to conduct yourself in an ethical manner and report those who do not.

Company chooses to promote ethical behavior. All unethical conduct, at every level, ultimately hurts the company and that ultimately hurts you. Even behavior which is performed in the name of the "company good" can be devastating. You only have to consider what happened to companies like Enron to see disastrous effects that seemingly innocent lapses in ethics had on the company. So if you know of any incidents of financial misconduct or ethical violations, it is your obligation and duty to Company, yourself and your coworkers to report it.

Q. I am not sure what I have observed or heard is a violation of company policy, or involves unethical financial conduct, but it just does not look right to me. What should I do?

File a concern and ask. EthicsLink is set up to ask questions as well as to file a report on conduct. We'd rather you asked than let possible unethical financial behavior go unchecked because you weren't sure.

Q. Where do these reports go? Who can access them?

Reports are entered directly on the EthicsLink secure server to prevent any possible breech in security. EthicsLink makes these reports available only to specific individuals within our company based on our report distribution guidelines. EthicsLink employees do not have access to the entire report only the names of mentioned individuals. The EthicsLink system and staff are trained and committed to ensure that no report is ever shared with implicated parties, their peers or subordinates.

Q. How do I know that something will be done about what I report?

When you file a report, you receive a unique user name and password. We suggest that you log back into EthicsLink within 48 hours to see the company response and to check if any further information is requested. If so, we hope you will give further clarification to help resolve the matter.

Q. Are these follow-on reports as secure as the first one?

All EthicsLink correspondence is held in the same strict confidence as the initial report.

Q. What if I want to be identified with my report?

There is a section in the report for identifying yourself, if you wish.

Q. Can I still file a report if I don't know how to use a computer or don't have access to the Internet?

You can file an EthicsLink report from any computer that can access the Internet. You can file from home - www.EthicsLink.com. Many public locations, including the public library, have Internet computers. If you don't have access or are uncomfortable using a computer, you can call the EthicsLink toll-free hotline 877-778-5400 which is available 24-hours a day.

Q. Is the telephone toll-free hot line confidential and anonymous too?

Yes, but no human interaction is ever as confidential as a report placed directed from your computer to EthicsLink. You will be asked to provide the same information that you would provide in an internet-based report and a team member at EthicsLink will be filing the report for you. These reports have the same security and confidentiality measures applied to them during delivery.