What is MyComplianceReport?

MyComplianceReport is a web-based portal supported by the third-party vendor, Ethico. It is a comprehensive and confidential reporting tool that enables Nakupuna Companies ("Nakupuna") employees, partners and other stakeholders to address fraud, abuse, and other misconduct in the workplace and promote a positive ethical and compliant culture that reflects Nakupuna's mission, vision, and values.

Why do we need a compliance hotline like MyComplianceReport?

By creating open lines of communication, we promote a positive work environment and maximize productivity. An effective reporting system will add to our other efforts to cultivate a culture of integrity and ethical decision-making.

Is MyComplianceReport and the ComplianceLine the same thing?

ComplianceLine is an all-inclusive term and refers to the MyComplianceReport web-based portal as well as the toll-free telephone number.

May I report using either the Internet or the telephone?

Yes. The ComplianceLine accepts confidential, anonymous reports via telephone 1-877-264-2741 or online at nakupuna.compliancelinemcr.com.

What types of situations should I report?

Any questions or concerns regarding actual or potential violations of the law, regulation, policy or procedure, and/or the Code of Business Ethics and Conduct ("Code") should be reported. Retaliation is prohibited for reports of alleged misconduct made in good faith.
Examples:

• Information Security/Data Privacy Issues - Lost/stolen device containing classified information, accessing information without professional need
• Specific incidents of unacceptable or disruptive behaviors (physical or verbal)
• Employee relations matters (hiring practices, retaliation, discrimination, harassment, workplace conflicts)
• Unsafe work environment (safety rules not followed, unsafe equipment, work hazard, etc.)
• Documenting or billing for services not provided
• Providing a kick-back or bribe to a public official or third party
• Using position or company resources for personal gain, non-work related reasons
• Ongoing, previously reported concerns that require an independent review

I am not sure if what I have observed or heard is a violation of Nakupuna's Code, policy, or involves unethical conduct, but it just does not look right to me. What should I do?

File a report. ComplianceLine can help you prepare and file your report so it can be properly understood. Nakupuna would rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked.

If I see a violation, shouldn't I just report it to my manager, security, or human resources and let them deal with it?

Nakupuna employees are responsible for reporting potential illegal or unethical behavior that violates the Code, the law, and/or regulations. Ideally, employees should bring concerns forward to their direct manager, HR representative, or member of Nakupuna's Management Team. Nakupuna recognizes, however, that there may be circumstances when employees are not comfortable reporting the issue in this manner. It is for such circumstances that we have partnered with Ethico – to obtain reports anonymously rather than employees not reporting concerns.

What information do I need to provide about my complaint?

The Compliance and Ethics Department 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 of when 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?

We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a safe and productive environment, and a culture of integrity.

Does management really want me to report?

Yes. In fact, Nakupuna needs you to report your concerns. Your reporting can minimize the potential negative impact on Nakupuna and our people.

Is my information secure??

MyComplianceReport utilizes the latest in 128-bit encryption technology. No data mining or off-site web hosting is used. All of your report information is kept in our highly secured facility.

Can I remain anonymous if reporting through the ComplianceLine?

Yes. The ComplianceLine 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 a Report Number that allows for anonymous communication with a member of the Compliance Department.

Where do these reports go? Who can access them?

Reports made through the ComplianceLine are maintained on a secure server. A limited number of Nakupuna managers/directors, including those in the Compliance Department and on the Compliance Committee, can access these reports.

Where do these reports go? Who can access them?

Reports made through the ComplianceLine are maintained on a secure server. A limited number of Nakupuna managers/directors, including those in the Compliance Department and on the Compliance Committee, can access these reports.

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

Confidentiality means that members of the Office of Talent Management and the Compliance and Ethics Departments 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 (or "anonymous") means that Nakupuna Personnel may report any concern through the Integrity Line 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 the Compliance and Ethics Department's permanent records.
• Information shared outside of the Integrity Line case review process is not protected by the Compliance and Ethics Department.
• Information shared through the Integrity Line may lead to indirect identification of a reporter given the specific details provided.

What if I want to be identified with my report?

There is a section in the report for identifying yourself, if you wish.

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 a Report Number that allows for anonymous communication with the lead investigator in the Compliance Department. The Report Number 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 ComplianceLine homepage, click 'Follow-up' to ask questions, provide updates or inquire about the status of the review.

How long will the investigation take?

Each allegation reported through the ComplianceLine 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 Number to check on the status of a review or communicate with the lead investigator.

Where do I get a Report Number if I do not already have one? What if I forgot my Report Number?

If you do not already have a Report Number or if you have lost or forgotten your Report Number, you will need to create a New Report. Once your report has been generated, you will be given a Report Number. You will then be able to check the status of your report by logging in at MyComplianceReport.com using your Report Number.