Lubrizol’s Ethical and Legal Conduct Guidelines

Lubrizol’s Guidelines on Ethical and Legal Conduct include the following text on how to ask for help, raise concerns, and seek clarification:

“You should never hesitate to ask a question or report a concern. If you become aware of a situation in which you believe Lubrizol’s ethical and legal guidelines have been violated, or if you feel you are being pressured or being asked to compromise your values, it is your responsibility to communicate this concern to the company. It is important for you to know that you will not be disciplined, lose your job, or be retaliated against in any way for asking questions or voicing concerns about our ethical or legal obligations, as long as you are acting in good faith. Good faith does not mean that you have to be right—but it does mean that you believe you are providing truthful information.

There are a number of people you can contact to ask questions or voice concerns. Your most immediate resource is your supervisor. She or he may have the information you need or may be able to refer the question to another appropriate source. There may, however, be times when you prefer not to go to your supervisor. In situations where you choose not to go to your supervisor, either because your supervisor does not have the information you need or because you desire confidential advice about an ethical or legal dilemma facing you, a network of regional ethics coordinators has been established. You may also call Lubrizol’s corporate ethics help line at 1- 440-943-1200, ext. 5000. This number rings in the office of Mark Meister, a vice president of the corporation, who is the Chief Ethics Officer and has sole responsibility for ext. 5000. If Mark is unavailable, you can leave your message on voice mail at ext. 5000 and he will receive it promptly. You may, but need not, leave your name and/or telephone number so he can get back to you for more facts.

When you call ext. 5000, this is what you can expect:

• Your report or concern will be taken seriously.

• The accuracy and completeness of your report will be investigated by persons who are not in the chain of supervision over you. Each report will be carefully evaluated before it is referred for investigation or resolution.

• Your report will be handled promptly, discreetly and professionally. Discussions and inquiries will be kept in confidence to the extent appropriate or permitted by law.

If you wish, you can obtain certain follow-up information about how the corporation addressed your report. Ext. 5000 is not equipped with caller ID, so the number from which you are calling cannot be identified or traced. Similar lines have been established in our facilities on a global basis. You should refer to your regional ethics coordinator for more information. In the event that an investigation is initiated, employees have a shared accountability to answer any questions truthfully and to the best of their ability. Concealing or covering up an ethical or legal violation is itself a major violation of our guidelines. If an individual engages in concealing or covering up such violations in the absence of significant, serious, mitigating circumstances, the penalty for such conduct would be immediate discharge. It also is expected that employees will cooperate fully if requested to do so in an investigation. Failure to cooperate could be construed as participating in concealment or cover-up activities. Your cooperation is appreciated.”

Workforce, June 2002, p. 32 — Subscribe Now!