1E9Ct5D

• Education of managers to ensure there is an understanding of the reasonsemployees are reluctant to report matters and training to assist managersin the proper handling and appropriate further internal communication ofreported concerns.• Institution of compliance related employee reporting review processes toensure that matters that are raised are appropriately considered andaddressed by qualified company officers.• Expansion of reporting mechanisms and features, including externallyhosted hotlines, to ensure that employees have multiple options andplaces to lodge concerns, on an anonymous basis if desired, and withoptions allowing for responses to reports of concerns or problems.These types of efforts have been successful in encouraging employees to come forwardand increase reporting.But there is still more that can be done. Management needs to do more to ensure thatall appropriate steps are taken to generate reports of problems regardless of whetheremployees desire to come forward or feel comfortable doing so. For example, ratherthan soliciting the typical one-time orientation certification that an employee hasreceived and agrees to comply with the corporate compliance program and code ofconduct, consider implementing an annual recertification process. In that process,employees are required to affirmatively confirm (by checking off on the form) that thatthey are not aware of any problems or conduct that is not in conformance with the17