Inquiry and Reporting Mechanisms

Help Lines

The 800 number is toll-free and has capability for the hearing-impaired and translation services, if needed. Outside of the United States, this number is accessible from anywhere in the world by calling the ATT operator in the country in question. The Help Line number is 1 (877) 319-0270.

In addition, employees can also report their concerns via https://dayzim.ipm.starcompliance.com. No action will be taken against those who report a suspected violation. There will be no retributions or reprisals for reporting a concern. Complaints can be filed anonymously. The Company does not attempt to identify anonymous complainants.

The employees, and others also have the option to report a concern to the Company's Ethics Officer. The names and contact information of the Ethics Officers are shown on Ethics Posters displayed at various locations throughout the Company.

All calls are categorized into three categories: A, B or C depending on the significance.

Status of Help Line complaints are reported quarterly to the appropriate business unit President, Ethics and Compliance Committee Members and the CEO showing the investigation status, resolution and corrective actions taken.

There is a formal protocol for handling Help Line complaints.

We have a 5-step process for handling a concern reported through our Help Lines:

1. Acknowledgement of the complaint received within 24 hours.
2. Assignment of the complaint to a subject matter expert for investigation or a response as needed.
3. Maintaining contact with the complainant regarding the status of the investigation.
4. Review of the report submitted by investigator for the thoroughness of the investigation and soundness of the resolution by the Head of Ethics and Compliance Program. 
5. Report back to the complainant regarding the resolution of their complaint.

Exhibit A - Investigation Checklist
Exhibit B - Fairness Confidentiality

As shown above, there is an increase in the number of calls received in 2018 compared to 2017. We believe this is due to the increase in awareness of our Help Line and employee belief that the Company takes all complaints seriously. We also noted that the percentage of anonymous calls has decreased by 5% . This is an indication of the awareness of the Company’s commitment to not retaliate for reporting a concern about a violation of the Code of Ethics.

Our recommended protocol for reporting a concern about violations of the Company’s Code of Ethics is for employees to report a concern to their immediate supervisor. However, we do not discourage anyone from reporting a concern through the Help Line. We remind employees that there will be no retaliation for reporting a concern about unethical behavior by anyone even if their reported concern is not substantiated. The Company will protect employees who refuse to act unethically to gain business. We also assure that our non-retaliation policy applies to all whistle blowers who report bribery and corruption incidents from all of our locations around the world including employees of joint venture partners.