Compliance Procedures

All employees must work to ensure prompt and consistent action against violations of this Code. However, in some situations it is difficult to know right from wrong. Since employees cannot anticipate every situation that will arise, it is important that employees have a way to approach a new question or problem. These are the steps to keep in mind:

  • Make sure you have all the facts. In order to reach the right solutions, employees must be as fully informed as possible.
  • Ask yourself: What specifically am I being asked to do? Does it seem unethical or improper? This will enable employees to focus on the specific question they are faced with, and the alternatives they have. Employees should use their judgment and common sense; if something seems unethical or improper, it probably is.
  • Clarify your responsibility and role. In most situations, there is shared responsibility. Are your colleagues informed? It may help to get others involved and discuss the problem.
  • Discuss the problem with your supervisor. This is the basic guidance for all situations. In many cases, an employee’s supervisor will be more knowledgeable about the question and will appreciate being brought into the decision-making process. Remember it is a supervisor’s responsibility to help an employee solve problems.
  • Seek help from Company resources. In the rare case where it may not be appropriate for an employee to discuss an issue with a supervisor, or where an employee does not feel comfortable approaching his/her supervisor with a question, the employee should discuss it with Human Resources or Legal.
  • You may report ethical violations in confidence and without fear of retaliation. The Company takes all reports seriously and handles them as quickly, thoroughly and confidentially as possible. While the Company cannot ensure complete confidentiality, to the extent possible, the Company will protect the report and investigation against unnecessary disclosure. Company does not permit retaliation of any kind against employees for good faith reports of ethical violations.
  • Always ask first, act later. If an employee is unsure of what to do in any situation, he/she should seek guidance first before the employee’s acts.