In a word, No.  The Company encourages Employees to report concerns directly to any individual with whom the Employee feels comfortable and who’s in a position to help, like a Manager, Executive, HR, or Ethics & Compliance.  (Gossiping to a co-worker, however, isn’t “reporting” anything; the report has to be to someone in a position of authority who can make sure the Company does something about it.)

Also, you can call the Ethics Helpline at 1-855-440-2672 if you’d rather report your concern over the phone.  The important thing is that you Speak Up and make your concern known!

If your concern is about a Conflict of Interest, you can report it in the same way as any concern.  You can also go to the NKNA Ethics & Compliance Department (“Ethics & Compliance”) SharePoint site, download a “Disclosure Form,” and submit your concern directly to Ethics & Compliance.  Or, heck, just ping E&C in any fashion, and they can help you from there.

Not if you don’t want the Company to know.  Whether you call the Helpline or report your concern here, you can choose to remain anonymous either way.  Of course, the Company encourages you to identify yourself because that makes any investigation way easier, but if you don’t feel comfortable doing that, you don’t have to.  And, no, the Company will not make any effort at all to figure out who you are, if you choose to remain anonymous.

The Company’s “Speak Up and Investigations Policy” tells you that if you become aware – in any way – of any possible violation of law, regulation, code, or Company policy (including the Code of Ethics & Conduct), you have an obligation to report your concern.  But to make it even easier on you, you should feel free to report anything that doesn’t sit right with you, even if you’re not sure whether it’s any kind of violation or otherwise unethical.

The Company’s “Conflicts of Interest Policy and Procedure” goes into great detail on what’s considered a “conflict of interest.”  But, again, we can make it even simpler for you.  If you feel like any employee – including yourself – is doing something that someone might view as benefitting the employee/you while in any way harming the Company’s interests, you should report it.  Many times, situations turn out not to be Conflicts of Interest, or the Company is able to arrange things so that a Conflict is avoided.  But we won’t know, and the Company can’t do anything, unless you report your suspicions.

Ideally, no, because your Manager has a duty to “report up” any concern that may involve legal or regulatory liability to the Company or where the conduct might violate any Company policy.  But there’s no harm in reporting your concern yourself because if your Manager can’t (or didn’t) resolve the concern himself or herself, or if you don’t know whether your Manager made a report, it’s better to be safe than sorry.  As you might imagine, the Company can’t resolve your concern unless it knows about it!

That’s fine.  The only way you could ever get in trouble when raising a concern is if you knew that your report was false.  If you’re reporting a concern in good faith, not believing that it’s untrue, no one can criticize or “punish” you for that.

• First/last name of person(s) or organization(s) engaged in alleged wrongdoing
• Description of the event, location, and date/time of when event occurred
• Specific details or synopsis of the concern(s) being raised
• First/last names of witnesses to the event or others who may have knowledge of the concern(s) being raised
• How the event was discovered if the reporter was not a participant or directly involved
• Supporting documentation if available, including policies, memoranda, emails, text messages, etc.

The Company will do everything it can to keep your report confidential, including telling only those folks who have a legitimate “need to know” about the report.  Obviously, anyone involved in the investigation is going to know about the concern, as will those Leaders who must be involved in the outcome, but even when the concern is known, the Company will take steps to protect your identity, even if you didn’t report anonymously.  In fact, the Company tries to protect confidentiality throughout the process, in order to protect the privacy rights of everyone involved, whether you, a witness, or an accused.

The information the Company requires in order to investigate your concern is pretty basic, and the Web Portal walks you through everything.  In a nutshell, the more you tell the Company about your concern, the more easily the Company can investigate it, get to the right conclusion, and fix any problem.

When someone’s actions violate our Code, our policies or procedures, or applicable laws or regulations, it can harm not only the involved parties, but our whole organization.  If a law is violated, the result could be civil or criminal action against our organization and/or the person(s) responsible.

We take any potential violation seriously. Reports of potential misconduct are reviewed carefully and steps are taken to correct the situation, including disciplinary action when appropriate.

You sure can.  There’s an upload button in the Web Portal, so you can add whatever you’d like to your report.

Report it.  The Company expects its business partners to act with the same high degree of ethics that Company employees must follow.  We may also discover that a business partner’s misconduct involves folks at the Company (whether as participants, witnesses, or victims).  The Company can’t “punish” a business partner the way it can discipline an employee, but there are other actions the Company can take to resolve such problems.

The simple answer is that the “Speak Up and Investigations Policy” walks you through each stage of a reported concern, from Intake/Triage/Assignment to Investigation to Report/Outcome to Corrective Action.  And the Company does all of this in a manner consistent with the Policy.  The harder answer involves Outcomes because the concern may turn out to be unfounded (or at least not “proved”), and most disciplinary action or corrective action isn’t generally known to employees (except to the wrongdoer, if there’s a disciplinary action).  So, just because employees don’t know the outcome doesn’t mean that the Company hasn’t taken appropriate action when a concern is shown to be valid and requires some type of corrective action.  We generally keep discipline and corrective action confidential, in order to protect everyone’s privacy rights and to avoid possible retaliation.

It varies with the complexity of the investigation.  Many matters can be resolved quickly, say within 30 days.  Other matters – usually involving complex facts, significant misconduct, or more senior personnel – will generally take longer.

It depends. Most “potential” or “apparent” Conflicts of Interest can be resolved through a conversation with the employee who allegedly has the conflict. Only if the Conflict of Interest is significant (material) and requires more digging would the Company treat it like any other investigation.

If you’re the one who reported the concern, the Company absolutely will want to speak with you about it because no one knows more about your concern than you do!  If you reported anonymously, the Company can interact with you through the Web Portal or through the Helpline without ever knowing who you are (because you get your own Case Number and Password to communicate through the Portal).  Of course, during an investigation, it’s possible that the Company will reach out to you directly because you may, logically, be a potential witness in the matter.  Even if the Company speaks with you directly, however, it will still never ask you – or try to find out whether – you’re the Reporter.

Woe be unto him or her!  The Company has a Zero Tolerance policy when it comes to retaliation against anyone involved in an investigation, including the reporter, any witnesses, and even the accused(s) (whom we call “Subjects”).  Retaliation under these circumstances will lead to disciplinary action, up to and including immediate termination of employment with the Company.  You get the picture – retaliation is unacceptable at the Company.