Ethics & Diversity – Accounting Concerns
Procedures for Accounting and Auditing Matters
The company is committed to achieving compliance with all applicable securities laws and regulations, accounting standards, and audit practices. Any employee of the company may submit a good faith complaint without fear of dismissal or retaliation of any kind. Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review. The company's Audit Committee will oversee treatment of matters submitted concerning this area.
In order to facilitate the reporting of complaints, the Company's Audit Committee has established the following procedures for (i) the receipt, retention and treatment of complaints regarding accounting, internal accounting controls, or auditing matters ("accounting matters") and (ii) the confidential, anonymous submission of concerns regarding questionable accounting or auditing matters.
Receipt of Complaints
Employees with concerns regarding accounting matters may report their complaints (on a confidential or anonymous basis if desired) either orally or in writing through the Integrity Helpline to the Office of the Ethics and Compliance. The contact information for the Integrity Helpline is as follows:
Telephone: 1-800-265-9381
E-mail: Ethics and Diversity Department
Mail: Ethics and Diversity Department
P.O. Box 52549
Houston, Texas 77502-2549
Scope of Matters Covered by These Procedures
These procedures relate to employee complaints relating to any questionable accounting or auditing matters, including, without limitation, the following:
- Fraud or deliberate error in the preparation, evaluation, review, recording, maintaining or audit of any financial statement of the company
- Deficiencies in or noncompliance with the company's internal accounting controls
- Misrepresentation or false statement to or by a senior officer or accountant regarding a matter contained in the financial records, financial reports or audit reports of the company
Treatment of Complaints
Unless determined otherwise by the audit committee (the senior vice president, general counsel and chief compliance officer, vice president of internal audit, company employees) will investigate the complaint as well as determine the appropriate report to be made to the company's external independent auditor.
Prompt and appropriate corrective action will be taken as warranted. The company will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee in the terms and conditions of employment based upon any lawful actions of such employee with respect to good faith reporting of complaints regarding accounting matters or otherwise as specified in Section 806 of the Sarbanes-Oxley Act of 2002.
Reporting and Retention of Complaints and Investigations
The Office of the Ethics and Compliance will maintain a log of all complaints, tracking their receipt, investigation and resolution and shall prepare a periodic summary report thereof for the audit committee. Copies of complaints and such log will be maintained in accordance with the company's document retention policy
