English - Prometric
English - Prometric English - Prometric
Treatment of Reports and Complaints: When you contact your manager, supervisor, HR, the Prometric legal department or the Prometric hotline, this is what you can expect: • Your question, report or complaint will be taken seriously, • Information will be gathered in response to your questions or concerns, • Your question, report or complaint will be forwarded to appropriate Prometric management for follow-up, • Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review, • Complaints and concerns relating to accounting, internal accounting controls or auditing matters will be reviewed under the Prometric Audit Committee’s direction and oversight by the Prometric General Counsel and Audit Director and/or such other persons as the Audit Committee determines to be appropriate, • Employees are obliged to cooperate with investigations relating to violations and complaints and must always be truthful and forthcoming in the course of these investigations, and • Prompt and appropriate corrective action will be taken when and as warranted. Retention of Reports and Complaints and Investigations: The office of the Prometric General Counsel will maintain a log of all reports and complaints related to accounting, internal accounting controls and auditing matters, tracking their receipt, investigation and resolution and will prepare a periodic summary of reports and complaints for the Audit Committee. Retaliation is Prohibited: We want you to know that we will not discharge, demote or suspend you if you provide information or assist in an investigating regarding conduct that you reasonably believe is unethical or that constitutes a violation of law, this Code or our other policies. This includes giving information in connection with an authorized investigation. However, we reserve the right to discipline you if you make an accusation without a reasonable, good faith belief in the truth and accuracy of the information or if you knowingly provide or make false information or accusations. “Good faith” does not mean that you have to be right – but it does mean that you believe you are providing truthful information. If you believe that you have been unfairly or unlawfully retaliated against, you may file a complaint with your manager or supervisor, the Prometric General Counsel or your Human Resources department. Presumption of Innocence: If someone makes a report or complaint against you, you will be presumed innocent unless the investigation reveals a violation has occurred. 28
Disciplinary Process: As noted previously, a violation of law, this Code or our other polices may result in disciplinary action up to, and including, termination and/or legal proceedings. Waivers: Waivers of this Code may be granted only by the Prometric General Counsel’s office; however, any waiver of this Code for Prometric executive officers or directors may only be made by the Prometric board of directors or a board committee and will be disclosed by Prometric to the extent required by law or regulations. Helpful Contact Information Prometric hotline o Internet: http://prometric.silentwhistle.com or www.prometric.alertline.com o Telephone: US: 1‐877‐874‐8416 Intl: 888‐690‐3864 General Counsel Attn: General Counsel Prometric, Inc. 1501 South Clinton Street Baltimore, MD 21224 United States email: anthony.scicchitano@prometric.com telephone: 443-455-6144 Human Resources Attn: Senior Vice President, HR Prometric, Inc. 501 South Clinton Street Baltimore, MD 21224 United States e-mail: kewin.gales@prometric.com telephone: 443-455-6848 .Chief Financial Officer Attn: CFO Prometric, Inc. 1501 South Clinton Street Baltimore, MD 21224 United States email: chris.derr@prometric.com telephone: 443-455-8566 29
- Page 1 and 2: Code of Business Conduct and Ethics
- Page 3 and 4: The Prometric Commitment Dear Prome
- Page 5 and 6: Protecting Company Assets and Resou
- Page 7 and 8: • Don’t send internal communica
- Page 9 and 10: Board Seats on Other Companies Obta
- Page 11 and 12: Protect the confidentiality of nonp
- Page 13 and 14: Accounting, Auditing or Disclosure
- Page 15 and 16: Media, Public and Governmental Inqu
- Page 17 and 18: Equal Employment Opportunities We p
- Page 19 and 20: Safe Working Conditions We are comm
- Page 21 and 22: Compliance with Laws, Rules and Reg
- Page 23 and 24: Contractual Authorization Don’t s
- Page 25 and 26: Fair Competition and Antitrust Comp
- Page 27: Disciplinary Action for Code Violat
- Page 31: Legal Notice This Code serves as a
Treatment of Reports and Complaints:<br />
When you contact your manager, supervisor, HR, the <strong>Prometric</strong> legal department or the<br />
<strong>Prometric</strong> hotline, this is what you can expect:<br />
• Your question, report or complaint will be taken seriously,<br />
• Information will be gathered in response to your questions or concerns,<br />
• Your question, report or complaint will be forwarded to appropriate <strong>Prometric</strong><br />
management for follow-up,<br />
• Confidentiality will be maintained to the fullest extent possible, consistent with the<br />
need to conduct an adequate review,<br />
• Complaints and concerns relating to accounting, internal accounting controls or<br />
auditing matters will be reviewed under the <strong>Prometric</strong> Audit Committee’s direction and<br />
oversight by the <strong>Prometric</strong> General Counsel and Audit Director and/or such other<br />
persons as the Audit Committee determines to be appropriate,<br />
• Employees are obliged to cooperate with investigations relating to violations and<br />
complaints and must always be truthful and forthcoming in the course of these<br />
investigations, and<br />
• Prompt and appropriate corrective action will be taken when and as warranted.<br />
Retention of Reports and Complaints and Investigations:<br />
The office of the <strong>Prometric</strong> General Counsel will maintain a log of all reports and<br />
complaints related to accounting, internal accounting controls and auditing matters,<br />
tracking their receipt, investigation and resolution and will prepare a periodic summary of<br />
reports and complaints for the Audit Committee.<br />
Retaliation is Prohibited:<br />
We want you to know that we will not discharge, demote or suspend you if you provide<br />
information or assist in an investigating regarding conduct that you reasonably believe is<br />
unethical or that constitutes a violation of law, this Code or our other policies. This<br />
includes giving information in connection with an authorized investigation. However, we<br />
reserve the right to discipline you if you make an accusation without a reasonable, good<br />
faith belief in the truth and accuracy of the information or if you knowingly provide or<br />
make false information or accusations. “Good faith” does not mean that you have to be<br />
right – but it does mean that you believe you are providing truthful information. If you<br />
believe that you have been unfairly or unlawfully retaliated against, you may file a<br />
complaint with your manager or supervisor, the <strong>Prometric</strong> General Counsel or your<br />
Human Resources department.<br />
Presumption of Innocence:<br />
If someone makes a report or complaint against you, you will be presumed innocent<br />
unless the investigation reveals a violation has occurred.<br />
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