Open communication is essential for accomplishing the goals of the Compliance Program. That objective is to minimize and prevent fraud, waste and abuse. The success of the Program depends on maintaining effective channels of communication. As an employee, you must be willing to bring forward problems and know that you will be listened to and taken seriously and you are protected from retribution for doing so.

Raising Questions and Concerns If you become aware of an activity that you think may be a problem, or if you have any questions about this Pledge of Principles or the Compliance Program, please contact your supervisor, the Legal department or the Compliance Department. If you are unsatisfied with the response or have additional concerns, you should continue to raise the issue through the supervisory structure or to the Corporate Compliance Officer.