What
about disciplinary action?
While adherence to law, regulation and
company policy, including the Standards, is the responsibility
of all employees, monitoring and enforcement of such compliance
is the responsibility of management with the support of the
Global Compliance and Business Practices department. Any violation
of a law, regulation or company policy can result in corrective
or disciplinary action up to and including termination. In
addition, you may be faced with disciplinary action, up to
and including termination, if you:
- Direct others to violate the law, regulations or company
policies,
- Fail to cooperate in a company investigation of possible
violations,
- Retaliate against another employee for reporting a concern
or violation, or
- Fail to effectively monitor the actions of people who
work for you.
The Global Compliance and Business Practices
department, in consultation with Human Resources, will recommend
appropriate discipline to management after a full investigation
and review of the facts. Management is responsible for implementing
corrective or disciplinary action.
May I report a concern directly to the
Board of Directors?
Anyone with a concern that they believe
warrants the attention of the Board of Directors may call
the Integrity Action Line and request that the report be routed
to the appropriate members of the Board. Reports regarding
accounting practices, internal accounting controls or auditing
matters will be routed to the Senior Vice President, Global
Compliance and Business Practices and the Audit Committee
of the Board of Directors as required. You may also write
to the Corporate Secretary in Kenilworth, New Jersey, and
request that the correspondence be forwarded to the Business
Practices Oversight Committee or particular members of the
Board. If you are unsure if a matter warrants the attention
of the Board you should contact your local Compliance Officer. |
