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CHAPTER 1

Asking Questions, Raising Concerns, and Getting Guidance

We have a clear responsibility and must have the courage to ask questions and raise concerns about compliance or ethical behavior. When you know of, or suspect, a possible violation, you have a responsibility to report, in good faith, that information to your supervisor. If, for any reason, you feel uncomfortable reporting issues to your supervisor, or if you believe your supervisor has not appropriately addressed an issue, you have other options. If you are uncertain whether your own conduct is proper, ask for help from any of the options available to you.

"Our challenge process depends on a willingness to respectfully engage in open, honest and objective debate. Each of us must challenge the status quo and humbly consider any challenges to our own beliefs, proposals and actions. This applies as much to challengers as those being challenged."

—Charles Koch

Options for Asking Questions, Raising Concerns and Getting Guidance

Speaking Up is Important

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Ways to Speak Up:

  • Your immediate supervisor
  • Any member of management
  • Any local or corporate human resources leader
  • Any member of Compliance and Ethics
  • Any lawyer in Legal
  • Contacting the GuideLine

You may report your concern online by visiting www.mykochguideline.com. International toll-free phone numbers are displayed once you have selected your Koch company and country location, if you prefer to contact the GuideLine by phone. Posters with international toll-free GuideLine numbers may also be posted in your workplace.

The GuideLine is operated confidentially by an independent third-party. It is available 24 hours a day, 7 days a week, to respond to your questions and concerns (anonymously, if you choose and as allowed by local law). It also offers multilingual services. The GuideLine specialists notify the Compliance & Ethics department, which will assess and determine appropriate action.

The GuideLine appropriately addresses the use, retention, transfer, disclosure and protection of any personally identifiable information contained within, including responsible and lawful collection and disposal.

FAQs

    What should I do if my supervisor asks me to do something that I think violates the Code or a company policy, or may be illegal?

    Regardless of who asks you, never do anything illegal. If you believe something you have been asked to do violates the Code or company policy, you must “stop, think and ask” before you act. If your concern is not appropriately addressed, you must report your concern to one of the many options available to you.

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    No-retaliation Policy

    Retaliation, retribution or harassment against any employee who, in good faith, asks any question or raises any concern regarding ethical behavior or compliance responsibilities is against company policy and is prohibited. “Good faith” does not mean that a reported concern must be correct, but it does require that you believe you are providing complete and truthful information when you report a concern or ask a question.

    FAQs

      Will I get into trouble if I call the GuideLine or inform management about an ethics issue and it turns out to be wrong?

      No. As long as you honestly have a good faith concern, our policy prohibits you from being retaliated against for simply raising your concern. Retaliation in any form is a violation of our policy. We expect you to voice concerns and questions about compliance and ethics issues using the many options available to you.

      All employees should practice respect and integrity at all times, whether they are reporting someone else or are the subject of a report themselves. If you feel you are being retaliated against, you must contact one of the options available to you.

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      Internal Investigation of Reports

      The company is committed to identifying and correcting wrongdoing wherever it may occur. All reported concerns will be promptly assessed and a determination made regarding the appropriate level of investigation and response. All employees are expected to cooperate fully with investigative efforts. This includes always giving truthful, accurate and complete answers, even if those answers are uncomfortable or create more questions. Investigations must be conducted by a resource suited to investigate the concern, appropriately considering the need for independence and impartiality. To the extent possible, the company will maintain confidentiality consistent with our legal and ethical responsibilities.

      Corrective Action and Employee Discipline

      Any employee who violates the law, the Code, or other company policies, standards or work rules will be subject to appropriate disciplinary action, up to and including termination, consistent with any applicable law, employment contract or bargaining agreement.

      The specific disciplinary action will depend on a number of factors, including, but not limited to:

      • The nature, severity and frequency of the violation.
      • The degree of knowledge and responsibility regarding the violation and the effect of the behavior on others, both inside and outside the company.
      • An employee’s degree of direct involvement.
      • An employee’s voluntary self-reporting of a violation and acceptance of their responsibility.
      • An employee’s history, including performance-related factors.

      Making Decisions with Integrity

      It is not always easy to determine the ethical or “right” thing to do in a particular business or work situation. Sometimes a law or policy clearly dictates the outcome, but often a situation will require interpretation to decide a fair and reasonable course of action.

      Thinking through a situation alone may not result in the same quality of decision-making as when we seek the knowledge of others. The engagement of other knowledgeable resources in the decision-making process increases the likelihood that all the facts and alternatives are considered.

      When making decisions, ask:

      • Are there other resources that could contribute?
      • Is it consistent with this Code and our Values? 
      • Is it the right thing to do?

      There are resources available to you to assist in resolving issues. You can ask your supervisor, any member of management, any local or corporate human resources leader, any compliance and ethics resource, or any lawyer in Legal.

      FAQs

        How do I know when I need to get help?

        Remember to “stop, think and ask.” Consider the following: Are your actions making you feel uneasy? Is your information correct and current? Are you rationalizing your actions? Are you saying to yourself, “Everybody does it”? How would your actions be perceived by others?

        Any discomfort should cause you to stop, step back, consider what you are doing, get advice and, if appropriate, redirect your actions so you are sure that you are doing the right thing.

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        Seven Element Risk Management System

        The company has implemented systematic programs to help ensure that business activities are conducted lawfully and with integrity.

         

        These programs typically address the following elements:

        1. Leadership and management commitment

        2. Employee ownership

        3. Compliance and risk assessment

        4. Compliance and risk management

        5. Communications and training

        6. Change management

        7. Continuous improvement

        There may also be Koch company specific standards, policies, procedures, practices, guidelines, work rules and other tools to govern your behavior and particular types of activities. If you have questions about them, contact your supervisor or your compliance and ethics resource for more information regarding the risk management system and other programs or tools that have been implemented in your Koch company.

        Audit and Advisory

        The company is committed to assuring proactive compliance with the law, our Values, the Code, company standards, policies, procedures, practices, guidelines and work rules. Audits and assessments are used to verify compliance, improve overall risk management, identify opportunities for improvement and educate employees. All of us must fully embrace audit activities and take appropriate corrective action. We are expected to give accurate and complete answers, even if those answers make us feel uncomfortable or create more questions.

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