EthicsLine Frequently Asked Questions

Why has Sterling contracted with Lighthouse-Services for reporting of matters?Lighthouse-Services is an independent third party that provides secure, confidential telephone and web-based systems for use by individuals who wish to report a concern or submit an inquiry relating to business conduct. Sterling is one of many companies that contracts with Lighthouse-Services for this service in the belief that potential reporters will be more comfortable reporting a concern if they know they will be reporting to a professional, third-party. The EthicsLine is available 24 hours per day, 7 days per week, 365 days per year. In addition, Lighthouse-Services offers translation services that allow telephone and web reports to be made in many languages.
What happens when I contact the EthicsLine?When filing a report, or just seeking advice, you will be asked to provide the most detailed information possible about the incident, or question. You may choose to remain anonymous when submitting your question or report; however, doing so may limit a full investigation of the matter.When submitting your question or report, you will be given a unique report number and asked to create a personal identification number, or PIN. You will need this information to access the follow up on a report you reported, or to add additional information. We ask you to follow-up on your inquiry or report within five to ten business days. Continued follow-up on a matter is particularly important for anonymous reports, where we have no other means to communicate with a reporter.
What if this is an emergency?Concerns about an immediate threat of physical harm or damage to property should not be reported to the EthicsLine. However, if you require emergency assistance, please contact your local emergency services, or hang up and call 911.
Should I report my concern through the EthicsLine, my supervisor or my Human Resources Representative?Sterling urges you to use the EthicsLine whenever you have a question or concern that cannot be readily addressed within your work group or through your supervisor. First consider whether you are comfortable raising your concern directly, such as to your supervisor or manager, your manager’s supervisor or your local HR Representative. Individuals within the Company have indicated that, while sometimes challenging, directly addressing issues and or concerns with those involved can be very effective. If you are uncomfortable reporting your concern, if you do not know whom to contact, if you believe your concern has not been satisfactorily addressed, or if you wish to remain anonymous, please proceed with the filing of a report through the EthicsLine.
Should I identify myself?If you choose to identify yourself in reporting your concern, Sterling will make every reasonable effort to hold your name in confidence during the investigation. Many investigations can be more quickly and effectively completed when the reporter is identified because it allows Sterling’s investigators to follow up directly with the reporter. Please note that if you are reporting about a personal concern involving your work schedule, benefits, pay or other employment-related matters, we may not be able to resolve it if you do not identify yourself. Please take this into account when filing your report.
What should I do if I lose my Report Number or PIN?If you no longer have your unique report number or PIN, you will no longer be able to access your report and you will be required to file a new report. The use of the report number and PIN is integral to maintaining a high level of confidentiality. You can mention in your new report that this matter relates to another report you previously filed.
What if I face retaliation?Sterling strictly prohibits any form of retaliation against any person who reports a concern. Complaints made in good faith will not expose you to any adverse action regardless of whether the concerns you report prove to be valid or result in any corrective action. If you believe you have faced retaliation of any kind, please report it to the EthicsLine so that Sterling can investigate.
Does management really want me to report?Yes! Reporting a concern can minimize the potential negative impact on the Company, and most importantly, help to alleviate a difficulty you might be facing. When necessary, Sterling will intercede in perceived ethical or business conduct issues. Also, offering input may help identify issues that can improve corporate culture and the Company’s overall performance. If you observe or suspect a violation of any Company workplace policy or of the law, as an employee, you have the obligation to speak up! Please do not assume that someone else is going to raise the concern. Unless you speak up, Sterling may not have the opportunity to investigate and address the situation.

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