Ethics Committee Rules

The committee also implements a confidential, neutral, informal process that facilitates the search for fair, equitable solutions to ethical problems that may arise at the company.

To fulfill its responsibilities, the Ethics Committee may serve as an information and communication source, a feedback channel, a dispute resolution expert and a source of ideas and suggestions.

1. The committee fully accepts and supports the "Ethics, Belief and Responsibility" program.
2. The committee keeps its business confidential.
3. The committee refrains from naming individuals or their supervisors and managers without the express consent of the principals.
   - During the deliberation process, the committee may communicate about the topic, as long as its communications do not result in the disclosure of the identity of the person(s) who originally brought the case to their attention.
   - All data disclosed by the committee must be carefully chosen to preserve the anonymity of the above persons.
4. The committee deems its communications with company employees "privileged" and further states that all committee members shall refuse to testify regarding their content for the purpose of any and all legal actions, both inside and outside the company.
   - Communications between a committee member and other individuals, when the member is acting in his or her official capacity, fall under this "privilege." With certain exceptions, individuals who speak to the committee must maintain the same level of confidentiality.
   - Committee members shall decline other responsibilities within the company that might compromise their ability to maintain the professional confidentiality their job requires.
   - The committee keeps no records for the company. If the committee believes it is necessary to write notes in order to perform its duties, it shall create and implement a uniform, invariable policy regarding the destruction of written notes, including e-mails.
5. The Ethics Committee decides alone and at its own discretion whether to take action based on the merits of the cases reported by individuals.
   However, the committee has the authority to refer matters to itself and to initiate action on a problem it perceives on its own.
6. Committee members are chosen for their neutrality and operate independently of management and the personnel hierarchy.
7. Each committee member strives to be objective and impartial.
   - The committee has a duty to consider the concerns of all parties involved in the issue under review.
   - Committee members do not act as attorneys or consultants for anyone.
   - The committee helps develop a set of options for the equitable resolution of the problems brought to its attention and facilitates discussion to identify the best solutions.
   - The committee makes no binding or mandatory decisions and enacts no policies. It does not decide questions concerning the company.
8. The Ethics Committee remains an informal resource, without written procedures. Official inquiries, for decision-making purposes, are conducted by others. In the event a committee member agreed, as a matter of exception, to act in an official capacity, said member would describe his or her responsibilities in advance in writing. Official inquiries are not subject to the normal confidentiality.
   - The Ethics Committee does not act on company orders or as a representative of the company. It always refers individuals to the contact person authorized to accept formal notices.
   - No one is ever obligated to meet with the Ethics Committee.
9. The committee takes care to communicate clearly with the individuals it interviews and contacts regarding the nature of its action.
10. Committee members strive to remain professionally up to date and competent.
11. The committee does its best to deserve the trust placed in it by the individuals it interviews and contacts.