Code of Conduct - Helpline FAQ
No. When calling the Help Line or submitting your online report, you are not required to disclose your name or identity.
- Calls are not recorded and no attempt is made to determine the number or location from which you are calling.
- If reporting online, the report cannot be traced back to specific computer.
- Should you choose to disclose your identity either via phone or online, it will be held in confidence to the fullest extent practical or allowed by law.
- The Help Line is managed by the GASCO Compliance Officer.
- GASCO has a non-retaliation policy included in its Code of Conduct.
- GASCO does not permit retaliation against an employee or other individual who, in good faith, reports a concern, issue, problem, violation of law, regulation, or other matter or participates in an investigation of such acts.
Concerns that can be addressed by the Help Line, include but are not limited to:
- Work Related Issues (e.g. sexual harassment, discrimination)
- Health, Safety and Environment Issues (e.g. reporting of injuries)
- Fraud, Theft or Kickback Issues (e.g. bribery, embezzlement)
- Management and Workplace Malpractices (e.g. contract and procurement irregularities, conflicts of interest, non adherence to a policy, falsifying documents).
- Privacy, Information Security and Misuse of GASCO Property (e.g. unauthorized use of proprietary information).
- Financial Management Issues (e.g. unauthorized expenditure of GASCO funds, overstatement of expenses)
- Violations of law.
For issues/concerns reported via phone:
You will be provided with a case number at the end of the call. The GASCO Compliance Office will ask you to call the Help Line again in approximately six weeks and provide the case number. You can then receive any response or resolution provided by GASCO or be requested for additional information to complete the evaluation.
For issues/concerns reported online:
Contact the Help Line toll-free telephone number approximately six weeks after your initial report submission and you can receive any response or resolution provided by GASCO.
However, any action taken against an employee as a consequence of the findings of the investigation may be personal and confidential, in which case, it cannot be disclosed.
Help Line is another means for you to report your concerns. It goes beyond traditional reporting mechanisms. It can be used, if for any reason you are unable to unwilling to report it through established channels.
It's a toll-free, confidential service that's available to take your calls.
We are committed to conduct our business with the highest levels of honesty and integrity. In order to ensure that we maintain and improve on the quality and integrity or our activities, it is important we provide employees and others with various methods to express concerns.
The Help Line (1-800-4423 or on-line through the GASCO website) provides an avenue for individuals to report concerns to GASCO anonymously and confidentially.
We encourage our employees, contractors, vendors, consultants, shareholders and other stakeholders to communicate directly and honestly about compliance issues or any other ethical concerns.
- GASCO is committed to promptly evaluate all reports of unethical or inappropriate activity.
- When a concern is reported to the Help Line, the specific action taken will depend on its nature and severity.
- Callers can be assured that the information provided will be evaluated and acted upon.
Still you should contact the Help Line. Most instances of malpractices e.g. fraud are discovered through tips from honest people who are not sure of the facts. This type of call is encouraged, as well as being acceptable.
The Help Line is available to GASCO's employees, contractors, vendors, consultants, shareholders and other stakeholders to communicate directly and honestly about compliance issues or any other ethical concerns.
Examples could be:
i. "Agree, but I can't actually say that"
This statement means someone is convincing himself/herself those half-truths or lies or OK. Both are dangerous - it's much better to deliver the whole bitter truth in a caring way.
ii. "Don't send me memos or email. Call instead"
Sometimes, when people ask this, they're trying to avoid a paper (or electronic) trail. Ask yourself why.
iii. "Shred these documents for me"
This could be an attempt to erase the paper trail.
iv. "Delete this email after reading"
This request is naive. Erasing electronic trails takes a lot more than the delete button in Outlook.
v. "Go through your files and remove and shred any document that refer to this"
This may be an attempt to remove the evidence of an improper act.
vi. "I'd like it to come from you"
Ask yourself, who should be the normal deliverer of "it"? Are you really the most competent/compassionate/articulate person around? If not, it's possible that delivering "it" could be dangerous.