Davis H. Elliot

What is MyComplianceReport?

MyComplianceReport is a web-based portal supported by the third-party vendor, ComplianceLine. It is a comprehensive and confidential reporting tool that enables all Davis H. Elliot Personnel to address fraud, abuse, and other misconduct in our environment and to promote a healthy and safe experience for everyone.

May I report using either the Internet or the telephone?

Yes. The Davis H. Elliot Compliance & Ethics Line accepts reports via telephone (888-856-3461) or the web form (www.davishelliotcompany.com).

Is MyComplianceReport and the Compliance & Ethics Line the same thing?

The Compliance & Ethics Line is an all-inclusive term and refers to the MyComplianceReport web-based portal as well as the toll-free telephone number.

Can I remain anonymous if reporting through the Compliance & Ethics Line?

Yes. The Compliance & Ethics Line does not attempt to identify reporters, whether submitting telephonically or electronically. Reporters have the option to remain anonymous or provide their name and other contact information. Reporters are provided with a Report Key that allows for anonymous communication with those responsible for addressing reporting events.

What types of situations should I report?

Any questions or concerns regarding actual or potential violations of applicable law, regulation, policy and procedure, Employee Handbook or the Davis H. Elliot Code of Conduct should be reported. Reporters are protected from retaliation for concerns raised in Good Faith (believed to be true). Retaliation will not be tolerated.

Examples include but are not limited to:

Unsafe work environment (safety rules not followed, broken equipment, inappropriate staffing requirements, etc.)
Specific incidents of unacceptable, inappropriate, or disruptive colleague behaviors (physical or verbal)
Employee relations matters (hiring practices, retaliation, discrimination, harassment, workplace conflicts)
Alcohol or drug abuse
Conflicts of Interest (competing against Elliot, inappropriate supplier affiliations and gifts, etc.)
Fraud or suspected fraudulent activity (deception, suppression, cheating or any other illegal means to facilitate the misappropriate of assets resulting in wrongful gains to self or any other individual(s) and wrongful loss to others.)
Inappropriate recordkeeping or accounting
Using position or company resources for personal gain and/or non-work related reasons
Violations of federal, state, and local laws and regulations
Ongoing, previously reported concerns that require an independent review
Questions or seek guidance on matters when it is uncomfortable speaking with a member of management

What information do I need to provide about my complaint?

Those responsible for investigating reported instances must receive specific details concerning the matter in order to facilitate a thorough review. Providing partial or incomplete information may result in case closure due to insufficient information. Information needed to complete a thorough review may include:

First/last name of person(s) or organization(s) engaged in alleged wrongdoing
Description of the event, location, and date/time when the event occurred
Specific details or synopsis of the concern(s) being raised
First/last names of witnesses to the event or others who may have knowledge of the concern(s) being raised
How the event was discovered if the reporter was not a participant or directly involved
Supporting documentation if available, including policies, memoranda, emails, text messages, etc.

Why should I report what I know? What's in it for me?

Davis H. Elliot is committed to define the standards of excellence through continuous improvement in Safety, Quality, and Productivity for the benefit of our Customers, Employees, and Suppliers; therefore, we must be compassionate and act with integrity. Davis H. Elliot personnel have an obligation to report unsafe practices, unethical behavior or violations pertaining to the Code of Conduct, Employee Handbook, policies and procedures, or applicable law or regulation. When someone's actions violate any of these, it can harm Davis H. Elliot, our Employees, our Customers, and our Suppliers. If a law is violated, the result could be civil or criminal action against Davis H. Elliot and the person(s) responsible

We take any potential violation seriously. Reports of potential misconduct are reviewed carefully, and steps are taken to correct the situation, including disciplinary action or termination when appropriate.

Where do these reports go? Who can access them?

Reports made through the Compliance & Ethics Line are maintained on the Ethico secure server. A limited number of employees within Davis H. Elliot can access these reports. These employees are specially trained to handle complex and sensitive matters in a confidential manner.

How long will the investigation take?

Each allegation reported through the Compliance & Ethics Line is unique, so the estimated time of completion depends on many factors, such as the complexity of the issue, the number of people involved, the nature and extent of documents or other evidence involved, and the urgency of the matter. Reporters may use the Report Key to check on the status of a review or communicate with the lead investigator.

How do I get updates from investigators? How do I share additional details? How do I know the outcome of my report?

Reporters are provided with a Report Key that allows for anonymous communication with the lead investigator. The Report Key is a form of a report identification number that allows the reporter to check on the status of a case review or communicate with the lead investigator. On the Compliance & Ethics Line homepage, click 'Follow-up' to ask questions, provide updates or inquire about the status of the review.

What does "confidentiality" mean? Is it the same as "anonymity?"

Confidentiality means those individuals with access to reported activity will not disclose information to individuals outside of the reasonable "need to know" standard. This includes information received, used, maintained or accessed during the course of normal duties, such as case reviews.

Anonymity means that personnel may report any concern through the reporting channels without disclosing their identity. Reports made in good faith will be taken and reviewed without an attempt to identify the reporter.

Be advised that:

There are circumstances in which confidentiality and anonymity may not be maintained, such as disclosures pursuant to a subpoena or court order, a lawful discovery request or a disclosure necessary to resolve a potential compliance matter.
Anonymity applies to an individual's identity.
Confidentiality applies to information received, used, maintained or accessed.
Reporters may choose to release their identity during or after a completed review.
Information about a reporter's identity, if provided, will be retained in Davis H. Elliot's permanent records.
Information shared outside of the Compliance & Ethics Line case review process is not protected by the confidentiality requirements maintained within the Compliance & Ethics Line and review process.
Information shared through the reporting channels may lead to indirect identification of a reporter given the specific details provided.