The Ethics & Compliance Hotline is a confidential way to report concerns about potential violations of our Code of Conduct, company policies, or applicable laws and regulations. It’s available to team members and other stakeholders who want to report a concern or ask an ethics or compliance-related question.
You should use the hotline whenever you observe or suspect misconduct, unethical behavior, policy violations, or illegal activity, especially if you are uncomfortable raising the concern through normal management channels.
You can use the hotline to report serious concerns or suspected violations involving the workplace, including conduct that may be unethical, illegal, or inconsistent with our Code of Conduct or company policies.
The hotline is available 24 hours a day, seven days a week through Ethico’s MyComplianceReport platform. You may choose to submit a report anonymously. Once submitted, your report is shared confidentially with the appropriate Springline team for review and follow-up.
Examples include:
Yes. You do not need proof of wrongdoing to make a report. If you have a good-faith concern or suspicion, you are encouraged to report it so it can be reviewed appropriately.
Yes. You may choose to remain anonymous when submitting a report.
The only information required is enough detail to help us understand the concern and begin reviewing it. If you’d like someone to contact you, you can choose to provide your name and contact information, but it’s not required.
Reports are handled as confidentially as possible. Information is shared only with those who need it to review and investigate the concern.
Yes. Reports submitted through Ethico are protected using industry-standard security measures. Information is stored securely and handled in accordance with confidentiality requirements.
To check the status of a report:
Your Report Number is created automatically after you submit a new report. Save it in a secure place, as you’ll need it to check the status of your report or respond to any follow-up questions.
If you’ve lost or forgotten your Report Number, it can’t be recovered for confidentiality reasons. You’ll need to submit a new report.
Provide as much detail as possible, including:
The more information you provide, the more effectively the concern can be assessed.
Yes. The hotline can also be used to seek guidance and clarity on Springline policy questions, ethics or compliance-related issues.
The company does not disclose the identity of a reporting individual except where required by law or as necessary to conduct a fair investigation.
Your report will be reviewed by the appropriate Ethics, Compliance, Human Resources, Legal, Security, or other designated personnel. The matter will then be assessed and, if necessary, investigated.
Investigation timelines vary depending on the nature and complexity of the concern. The company strives to review and address all reports as promptly as possible.
Where possible, updates may be provided through the hotline system. However, specific details about investigations or disciplinary actions may not be shared due to privacy and confidentiality obligations.
No action will be taken against individuals who raise concerns in good faith, even if the investigation determines that no violation occurred.
The company prohibits retaliation against anyone who, in good faith, reports a concern, participates in an investigation, or seeks guidance regarding ethical or compliance matters.
Report the matter immediately through the hotline, Human Resources, Compliance, Legal, or another designated reporting channel. The company takes allegations of retaliation seriously and will investigate them.
Good faith means you genuinely believe the information you are reporting may be true, even if it is later determined that no violation occurred.