SEKO - Global Policies & Employee Handbook 2019

E-Mail: reports@lighthouse-services.com (must include company name with report) Fax: Fax alternative for written documents: 215-689-3885 (must include company name with report) Safeguards Confidentiality 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. However, your identity may become known during the course of the investigation because of the information you have provided. Reports are submitted by Lighthouse, the Anonymous Hotline reporting service, to SEKO or its designee, and all reports will be investigated at the sole discretion of our company. Timing Keep in mind that 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. How Reports will be Handled The action taken will depend on the nature of the concern. A number of SEKO nominated individuals or designees will each receive a copy of the report and follow-up reports on actions taken by the company. Initial inquiries will be made to determine whether an investigation is appropriate, and the form that it should take. Some concerns may be resolved by agreed upon action without the need for an investigation. Harassment or victimization of individuals submitting hotline reports will not be tolerated. Malicious allegations may result in disciplinary action.

Feedback to Reporter Whether reported directly to SEKO personnel or through the hotline, the individual submitting a report will be given the opportunity to receive follow- up on their concern: • Acknowledging that the concern was received; • Indicating how the matter will be dealt with; • Giving an estimate of the time that it will take for a final response; • Telling them whether initial inquiries have been made; • Telling them whether further investigations will follow, and if not, why not. Further Information The amount of contact between the individual submitting a report and the body investigating the concern will depend on the nature of the issue, the clarity of information provided, and whether the employee remains accessible for follow-up. Further information may be sought from the reporter. Outcome of an Investigation At the discretion of the company and subject to legal and other constraints the reporter may be entitled to receive information about the outcome of an investigation.

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