The Company believes it promotes a positive workplace environment through the following:
Ethics Hotline Program
We continously monitor and enforce compliance with our Code of Ethics and Corporate Responsibility and other corporate policies through confidential and
non-confidential reporting mechanisms. An anonymous hotline, mail, and email are the primary means for reporting
fraud or ethics violations in a confidential manner. Face-to face meetings are also encouraged with the Company's
All information reported by our employees is reviewed by the General Counsel, HR Department and/or our Compliance Officer and follow-up investigations are conducted, as appropriate.
The General Counsel ensures that there is no retaliation against any employee who has utilized our reporting mechanism to come forward with concern about their co-workers, supervisor or
Deterrence, Detection, & Remediation of Fraud
Our anti-fraud program and internal controls have been implemented throughout the Company and they are considered
an entity-level control which management relies upon to establish the Company's "tone at the top" relative to
fraud and financial reporting. The program and controls address each element of the Internal Control-Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission, generally known as the COSO framework. Accordingly, it is tested at Corporate, at Level 1 locations, and Level 2 locations selected for entity-wide testing and the
use of an internal control questionnaire.
We evaluate the effectiveness of our anti-fraud program through a detailed analysis
of specific organizational policies and procedures. Through discussions with management, each part of our Ethics Program is compiled and reviewed for appropriateness and availability to appropriate personnel.
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