1.15 · The Way We Work
Talk to Us
We encourage you to bring your questions, suggestions, and concerns to our attention. We will carefully consider each of these in our continuing effort to improve operations. Choosing to speak up about workplace concerns helps to build a healthy, ethical, and compliant workplace, and it is part of our culture. The Company encourages employees to speak up and to raise questions and concerns promptly about any situation that may violate our Code of Conduct, our core values, or our policies. We know our people are our most valuable asset, and it benefits all of us when concerns are raised so that the Company may consider them carefully and address them properly.
The Company is deeply committed to promoting a culture of ethical conduct and compliance with:
- Our Code of Conduct, our core values, and our policies
- The laws, rules, and regulations that govern our business
- Best practices in accounting, auditing, and financial reporting
We expect all of our employees, supervisors, directors, and agents to follow this commitment in every aspect of their work. We promote an environment that fosters honest, good faith communications about matters of conduct related to our business activities, whether that conduct occurs within the Company, involves a contractor, supplier, consultant, or client, or involves any other party with a business relationship to the Company. Consistent with our commitment to ethics, compliance, and the law, we welcome your good faith questions and concerns about any conduct you believe may violate our policies, especially conduct that may be illegal, fraudulent, unethical, or retaliatory.
If you have a problem or concern other than one covered by the harassment, retaliation, and discrimination Complaint Procedure, it is usually best to first present the situation to your supervisor so that the matter can be settled by examination and discussion of the facts. We hope your supervisor is able to satisfactorily resolve most matters.
If you still have questions after meeting with your supervisor, or if you would like further clarification, request a meeting with any office personnel. They will review the issue with you and discuss possible solutions.
Your suggestions and comments on any subject are important. We encourage you to take every opportunity to discuss them with us. Your job will not be adversely affected because you choose to use this procedure.
If at any time you do not feel comfortable speaking with your supervisor or the next level of management, discuss your concern with any other member of management with whom you feel comfortable.
The Company recognizes that coming forward with questions or concerns can sometimes feel like a difficult decision. We are committed to fostering an environment that does not deter individuals from speaking up when they observe conduct that may violate our policies or applicable laws. The Company will not tolerate retaliation of any kind because an employee in good faith raises a question or concern about a violation or suspected violation of our policies or the laws and regulations under which we do business, or because the employee participates in or cooperates with an investigation of such concerns.
Retaliation is any conduct that would reasonably dissuade an employee from raising, reporting, or communicating about good faith concerns through our internal reporting channels or with any governmental authority, or from participating in or cooperating with an investigation or legal proceeding raising such concerns. Retaliation may take many forms, including actual or implied threats, verbal or nonverbal behaviors, changes to the terms or conditions of employment, coercion, bullying, intimidation, or deliberate exclusionary behaviors.
The Company cannot correct problems unless it is aware that they exist. We ask employees raising concerns to provide as much detailed information as possible, including background and history, names, dates, places, and the reasons the situation is a cause for concern. This is especially important for concerns raised anonymously, so that the Company may conduct an appropriate review and, if necessary, begin an investigation.
The Company is committed to reviewing all reported concerns, conducting fair and thorough investigations tailored to the circumstances, and taking appropriate remedial and concluding steps as warranted. All action taken by the Company in response to a concern will depend on the nature and severity of the concern. When an employee raises a concern, the Company will maintain confidentiality to the fullest extent possible, consistent with applicable legal requirements and the need to conduct an adequate investigation. The Company expects that concerns will be submitted in good faith and that employees will participate truthfully in any investigation arising from a concern submitted under this policy. All good faith concerns and reports raised under this policy will be taken seriously.
Nothing in this policy prohibits anyone from electing to report concerns to, make lawful disclosures to, provide documents or other information to, or communicate with the Equal Employment Opportunity Commission, the National Labor Relations Board, the Securities and Exchange Commission, the Florida Commission on Human Relations, or any other federal, state, or local agency about conduct believed to violate laws or regulations. The Company also does not prohibit employees from participating in an investigation or proceeding conducted by one of these agencies.