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Since its introduction in 1995, Colgate’s Code of Conduct Hotline has helped to ensure that Colgate’s business is conducted in accordance with the highest ethical standards.
The purpose of the Code of Conduct Hotline is:
To provide Colgate people with advice and to help clarify how the Code of Conduct might apply to specific situations
To provide an alternative means of communication for people to bring information about suspected conduct, violations of the law, or activities in conflict with the Code of Conduct to the Company’s attention.
We encourage you to contact Global Ethics and Compliance to ask questions about, or to report any suspected violations of, the Code of Conduct. All reported violations will be promptly investigated. It is imperative that reporting persons not conduct their own investigations as investigations may involve complex legal issues.
We encourage you to identify yourself when calling the Code of Conduct Hotline to facilitate the investigation and follow-up. Where local law permits, you may submit information on an anonymous basis. There are laws in some countries that restrict the type of information you may report through a hotline. If these laws apply to your situation, a Global Ethics and Compliance representative will refer you to someone in your business unit who can assist you with your question or concern.
For the purpose of investigating a suspected violation of the Code of Conduct or Business Practices Guidelines, it may be necessary to transfer personal data collected in one country to other countries. Further, any actual or suspected violation of the Code or Business Practices Guidelines might result in a report being made to the Global Ethics and Compliance Department which may contain personal data. In such cases, personal data may be used by Company employees and Colgate entities that participate in the operations of the Global Ethics and Compliance Department to investigate the report, but only for such period as is reasonably necessary for this purpose (and thereafter such personal data will be destroyed or retained as required by Company policy or by law).
The Code of Conduct Hotline can be reached from anywhere in the world by telephone, fax, e-mail or letter as follows:
24-hour Hotline: (800) 778-6080 (toll free from U.S.,
Canada and Puerto Rico)
(212) 310-2330 (collect from all other locations)
Confidential Facsimile Number: (212) 310-3745
Confidential E-mail: firstname.lastname@example.org
Postal Address: Global Ethics & Compliance
300 Park Ave, 8th Floor
New York, NY 10022
Concerns and questions relating to accounting, internal accounting controls, financial policy, risk management or auditing matters are immediately brought to the attention of the chair of the Audit Committee of Colgate’s Board of Directors and handled in accordance with the procedures established by the Audit Committee. Under these procedures, the Global Ethics & Compliance Department, in conjunction with the Company’s Internal Audit and Corporate Legal departments, addresses these concerns in accordance with the directions of the Audit Committee chair. The Audit Committee chair approves recommendations regarding the handling of each matter, oversees any investigations and approves the disposition of each matter. In the Audit Committee chair’s discretion, he or she may engage outside counsel and other independent advisors.
No adverse action will be taken against anyone for complaining about, reporting, participating or assisting in the investigation of a suspected violation of the Code of Conduct, unless the allegation made or information is found to be intentionally false. To the maximum extent possible, Colgate will maintain the confidentiality of all complaints.