Ways to Report Illegal or Unethical Behavior
If you experience or witness any violation of the Code, you are encouraged to come forward. However, we know it is not always easy or comfortable to do so. That is why we offer a number of ways for you to be heard:
- Speaking with your supervisor or manager
- Speaking to Human Resources
- Speaking to the Legal Department at 407-333-7440
- Reporting through the Company’s Ethics Hotline at:
Cooperation with Investigations
We will investigate all reported concerns, and we expect all Team Members to cooperate fully in investigations. This includes participating in and being forthcoming during interviews; providing documents and other information as requested by the investigator; and volunteering relevant information even if we have not specifically requested the information. We will make every effort to maintain the confidentiality of our investigations as is appropriate under the circumstances or required by law.
We want our Team Members to feel safe when they report potential violations of the Code. Managers and other Company leaders are prohibited from retaliating against a Team Member for raising in good faith a Code violation or other concern. Examples of retaliation can include demoting, transferring, or terminating a Team Member for raising a question or speaking up in good faith about a possible violation of the Code. If you feel that you have been retaliated against for reporting potential misconduct in accordance with the Code, do not hesitate to contact your manager, Human Resources, or our Ethics Hotline. We will promptly and fully investigate your complaint and take appropriate disciplinary action, up to and including termination to prevent retaliation in the workplace.
Senior Employee Reporting Obligations
Senior Employees shall promptly bring to the attention of the General Counsel, Chief Compliance Officer, or the Chief Executive Officer and the Audit Committee any information concerning any violation of the Code, including any actual or apparent conflicts of interest between personal and professional relationships involving any management or other Team Members who have a significant role in the Company’s financial reporting, disclosures, or internal controls.