Moody’s Integrity Hotline (“the Hotline”) is provided by Moody’s Corporation (“Moody’s”). The website through which you may report an incident, is operated by NAVEX, established at 5500 Meadows Road in Oswego, Oregon in the United States (“NAVEX”).
The Hotline is used for reporting concerns about accounting, accounting controls, auditing, and corrupt practices. The use of the Hotline is voluntary.
Please note that while colleagues are encouraged to identify themselves when making reports to the Hotline, they are not obligated to do so.
Moody’s may collect the following information through the Hotline: your name, title and contact details; the name and other data about individuals that are named in your report; a description of the conduct at issue in your report including the date and location, as well as other pertinent information; and any questions you may have. Moody’s may also collect information from others (such as your colleagues) during any subsequent investigation.
The information provided by you will be treated confidentially.
Moody’s may use the information mentioned above because we have to either comply with a legal obligation imposed on Moody’s or we have a legitimate interest to investigate the report that you submitted to us.
When you call into the Hotline, a representative from NAVEX will answer your telephone call. NAVEX does not capture the telephone number of any incoming calls so that your call-in information can remain anonymous. You will speak with a Communication Specialist who will ask you for several items of information, document your input, and ask follow-up questions to clarify information. Please note that the Communication Specialist is not able to answer any questions about ethics or policy and cannot advise you on any course of action.
After the initial report or inquiry is made, a detailed record is prepared and sent by NAVEX directly to Moody’s Compliance and Legal departments. Depending on the nature of the matter, the Compliance department may communicate the report and related documentation to appropriate personnel at Moody’s who may need to be informed, such as representatives of Human Resources (“HR”) or Internal Audit for further investigation and resolution. Where necessary, the Compliance department may also need to notify members of HR or Moody’s management of any finding of violation for purposes of determining any disciplinary action and for transparency purposes. The information may also be shared with Moody’s external advisers (such as lawyers and/or auditors) and competent authorities (such as regulators and/or police).
Moody’s aims to inform each person implicated in a report about the allegations against him or her within an appropriate time frame, but will seek not to disclose your identity. Implicated individuals will have the right to react to the information reported by you. Please note that the information you supply may result in decisions that affect colleagues of Moody’s and other third parties involved in the relevant incident. We therefore ask you to provide only information that, to the best of your knowledge, is accurate. Knowingly providing inaccurate or misleading information may result in disciplinary actions or even civil or criminal liability. Also, where possible, any report should be limited to facts that are relevant to the report and the follow-up investigation.
Retaliation against any Moody’s employee who seeks advice, raises a concern, or reports misconduct in good faith is strictly prohibited. Any person found to have retaliated against an individual for making a report in good faith or for participating in an investigation of allegations of such conduct, will be subject to appropriate disciplinary action up to and including termination. If you think that you, or another employee, have been retaliated against for raising a concern, you should contact a member of the Compliance, HR or Legal departments, or call the Hotline immediately.
Moody’s has contracted with NAVEX to protect the confidentiality and security of your personal data, and NAVEX is only permitted to use your personal data for the provision of the Hotline. Information we receive from NAVEX and any personal information that you provide to us will be stored in a Moody’s database with limited access.
Beyond NAVEX, other transfers of personal data may take place to countries that have different data protection rules than are found in the country where you work, including to other Moody’s affiliates (see Moody’s latest 10-K filing to the U.S. Securities and Exchange Commission, available at http://ir.moodys.com/news-and-financials/sec-filings/default.aspx) or vendors, as required to investigate the report and administer the Hotline. Note that some of the non-EEA countries are recognized by the European Commission as providing an adequate level of protection according to EEA standards (the full list of these countries is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm.
We have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your data at all times. If you are based in the EEA, you may obtain a copy of these measures by contacting your local Human Resources representative.
Information relating to a report made via the Hotline will be archived or deleted based on the following criteria: when the investigation has been closed and no further action is needed; when the time period for any relevant litigation has lapsed; and when our obligations for record keeping relating to investigations have lapsed.
If you would like to request to review, correct, update, suppress, restrict or delete personal data, or if you would like to request to receive an electronic copy of such personal data for purposes of transmitting it to another company, you may contact your local Human Resources representative. We will respond to your request consistent with applicable law. If you have any questions or concerns, please contact your local Human Resources representative.
If you are based in Germany and you would like to contact the Data Protection Officer, you may do so by emailing privacy@moodys.com.
If you are based in the EEA, you also have the right at all times to lodge a complaint with a supervisory authority competent for your country or region, or of an alleged infringement of applicable data protection law.
Questions about the Hotline also may be directed to the above address.