IV. SAFEGUARDS
Harassment or Victimization Harassment or victimization of individuals submitting hotline reports will not be tolerated. Confidentiality Every effort will be made to protect the reporter's identity by our hotline vendor. Please note that the information provided in a hotline report may be the basis of an internal and/or external investigation by our company into the issue being reported. It is possible that as a result of the information provided in a report the reporter's identity may become known to us during the course of our investigation. Anonymous Allegations The policy allows employees to remain anonymous at their option. Concerns expressed anonymously will be investigated, but consideration will be given to:
The seriousness of the issue raised; The credibility of the concern; and
The likelihood of confirming the allegation from attributable sources. Malicious Allegations Malicious allegations may result in disciplinary action. V. PROCEDURE Reporting
The whistleblowing procedure is intended to be used for serious and sensitive issues. Serious concerns relating to financial reporting, unethical or illegal conduct, should be reported in either of the following ways: Website www.lighthouse-services.com/creallc English speaking USA and Canada: (844)490.0002 E-mail reports@lighthouse-services.com (must include company name with report) Fax alternative for written documents: 215-689-3885 (must include company name with report) Reporters to the hotline will have the ability to remain anonymous if they choose. Please note that the information provided by you may be the basis of an internal and/or external investigation into the issue you are reporting, and your anonymity will be protected to the extent possible by law. Reports are submitted by Lighthouse to CREA or its designee and may or may not be investigated at the sole discretion of our company. Employment-related concerns should continue to be reported through your normal channels such as your supervisor, local HR representative, or to the Chief Human Resource Officer (317.808.7285). Timing The earlier a concern is expressed, the easier it is for us to take action. Evidence Although you are not expected to prove the truth of an allegation, the employee submitting a report needs to demonstrate in their hotline report that there are sufficient grounds for concern.
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