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Code of Ethics Strengthening the Whistle-blowing

The following rules constitute the Company’s Code of Ethics (the “Code”). This Code is intended to aid Associates in making ethical and legal decisions when conducting Company business and performing their day-to-day duties. As used herein, the principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions are sometimes also referred to as the “Senior Financial Officers”. This Code has been reasonably designed to deter wrongdoing and to promote: honest and ethical conduct, including the ethical handling of actual and apparent conflicts of interest between personal and professional relationships; full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files with, or submits to, the SEC and in other public communications made by the Company; compliance with applicable governmental laws, rules and regulations; the prompt internal reporting to ...
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The Role of Technology and the Media

Whistleblowing has been the subject of recent controversies due to the rise of WikiLeaks and other whistleblowing websites. These websites mark a new form of whistleblowing only possible because of the Internet and computers as well as connected media partners worldwide. However, whistleblowing has relied on technology and media for a long time. Cryptome has accepted documents online for sixteen years. Daniel Ellsberg used a copier to copy the Pentagon Papers so he could give them to the New York Times. The technology involved in whistleblowing has changed drastically over time. At its most basic level, writing and speech could be used to convey information about wrongdoings. The printing press and radio eased the spread news. Copiers allowed whistleblowers to copy documents and give them to the press. Computers and the Internet make it easy to spread information and upload leaked documents. Easy uploading means the rise of leaking, mass release of millions of documents t...
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Whistle-blower Protection Policy

Federal laws prohibit retaliatory action by public companies against their employees who take certain lawful actions when they suspect wrongdoing on the part of their employer. In furtherance of the Company’s obligations under federal law, neither the Company nor any of our officers, employees, contractors, subcontractors or agents, may discharge, demote, suspend, threaten, harass, or in any other manner discriminate against an employee because of any lawful act done by the employee to: provide information to or otherwise assist in an investigation by a federal regulatory or law enforcement agency, any member of Congress or committee of Congress, or any person with supervisory authority over the employee (or such other person working for the Company who has the authority to investigate, discover or terminate an employee), where such information or investigation relates to any conduct that the employee reasonably believes constitutes a violation of federal mail fraud, wire fraud, b...
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Top 10 Ways To Minimize Whistleblower Risks

Here are the TOP 10 STEPS public and private employers should consider taking to minimize the risk of whistleblower retaliation claims and build defenses where litigation is unavoidable. 1. Conduct focus groups & surveys Develop an understanding of your workforce’s beliefs about whistleblowing and attendant retaliation risks through focus groups and surveys. Design questions that will expose whether employees are apt to bypass internal compliance channels (or not complain at all) and why. Focus groups should be diverse in terms of age, length of service, race, responsibility and education. 2. Create and widely disseminate whistleblower protection policies with multiple avenues for reporting Create and modernize policies on which employees can rely. In addition to codes of conduct, promulgate simple and straightforward whistle-blower protection policies. Include them in employee handbooks and make them available through multiple other channels. Ens...
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Internal Wistleblowing

Internal Wistleblowing refers to any time that a member of an organization (or a former member) tells someone else about an illegal or immoral practice, if the telling is done in the hope that someone will do something to change the practice. In the great majority of cases, employees tell someone within the organization and don’t want to cause any bad publicity for the organization—this is sometimes called internal whistle blowing, though we prefer to call this  internal reporting .  When organizations punish or discourage internal reporting, bad practices typically get worse, until someone—often motivated by conscience—feels they must notify the press, or a government agency. This is known as external whistle blowing, and it can mean serious problems for the organization. From an Ethical Systems perspective, internal reporting is vital to the health of organizations. Companies that don’t make it easy for their employees to report small problems internally are likely ...
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5 of the Most Famous Whistleblowers

Department of Veterans Affairs physician Katherine Mitchell risked her career to expose the VA’s recent manipulation of scheduling data. Bob Woodward’s “Deep Throat” helped bring the Watergate scandal to light. Whistleblowers play a critical role in government accountability, and the Senate recognized that fact on Wednesday by passing a resolution designating July 30, 2014 as National Whistleblower Appreciation Day. The vote came by unanimous consent on the 236th anniversary of the first whistleblower law. According to Sens. Chuck Grassley (R-Iowa) and Ron Wyden (D-Ore.), who sponsored Wednesday’s resolution, the original measure was enacted on July 30, 1778. It said: “Resolved that it is the duty of all persons in the service of the United States … to give the earliest information to Congress or any other proper authority of any misconduct, frauds or misdemeanors committed by any persons in the service of these states, ...
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