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Corporate H.R. Officers (C.H.R.O.M.E.)
March 18, 2018  
Corporate H.R. Officers (C.H.R.O.M.E.)
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Security and white-collar crime
February 27, 2007
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1. Do you have a policy in place to monitor employees to prevent malpractice or are you prepared to tackle potential incidents after-the-fact?

Our code of conduct policy and a business behavior policy governs all employees, and include references to willful misconduct and unethical behavior. We also have a performance development process in place to monitor job performance. We do not have a policy for "monitoring" associates. We do monitor, however, the use of company IT resources. We preface that with new-hire training and notices that pop up whenever an associate boots up their computer regarding appropriate use of the company electronic resources.

2. How do you balance a company's right to security with an employee's right to privacy? And how successful do you think the policy is at preventing incidents of bad behavior?

We create an expectation for limited privacy at the beginning of the employment relationship. Associates are told their work computers are company property subject to review at any time with or without their knowledge. The same privacy expectation is created for work spaces, such as offices, cubicles, lockers, parking lots, etc. As for the success of the policy, it's more about creating an ethical climate and having a recourse when incidents do occur rather than creating a police state. Our employees are aware of the policies and our hiring efforts focus on bringing on associates who demonstrate ethical behavior as well as job knowledge and experience. Additionally, we have a hotline in place to allow associates to report suspicious or bad behavior - they can identify themselves or report anonymously, and the report is handled by a third party vendor who then informs the company.

3. Do you have the capability and expertise within your organization to investigate a potentially criminal incident in-house or would you be forced to hire investigators from outside?

Our internal security department has in the past directed any necessary investigations. As warranted, they have involved outside security resources as appropriate.

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