As part of the company’s commitment to an ethical workplace and to ensure that the company meets its legal obligations, the company requires colleagues and associates to report possible violations of the company Code of Conduct. The company, through the Corporate Compliance Department (“Compliance”), responds to these reports. Compliance also tracks these incidents and reports them to the Board of Directors.
Compliance has primary responsibility to ensure that a detailed investigation of any possible misconduct has occurred. Compliance, therefore, depends on its colleagues in key internal departments to notify our group when these matters arise. These notifications are essential to allow Compliance to track the incident.