We understand that this Code of Conduct cannot cover every situation or answer every question that you may encounter in your work with Arch. Situations that involve questions of ethics and values are often complex and ambiguous. Sometimes a law or Company policy will guide you, but often you will need assistance interpreting complex regulations or applying a policy to a specific situation.
If you suspect a violation of law or Company policy, or if you have knowledge of other improper activities at Arch, you are required to report the situation immediately. Even if it's difficult to raise a concern, it's important to remember that serious damage to our reputation, to employee health and safety and to our customers, communities and shareholders may result if the concern is not addressed appropriately.
The Ethics Office
The Ethics Office serves as a resource to provide employees with advice, clarification and assistance in applying our Company policies and Code of Conduct. The Arch Ethics Officer works together with location and Business Ethics Officers to:
Asking for Guidance and Reporting Concerns
You may ask questions, raise issues and report your concerns to a number of Company resources. Issues and concerns may be communicated by telephone, by letter, through e-mail, in person or by contacting the Arch Help-Line.
Generally, your supervisor or manager will be in the best position to answer your questions or resolve your issue in a timely manner. If you are uncomfortable talking with your supervisor or manager about the issue, you may use any of the contacts below:
The Arch Help-line: 24-hour Confidential Telephone Assistance
We understand that you may have concerns about confidentiality and we respect the desire for anonymity in certain situations. That is why we created the Arch Help-Line. Any Arch employee or other third party including customers, shareholders, contractors, suppliers, agents or other representatives may call the Arch Help-Line. All calls to the Help-Line will be held in strict confidence. When you call, you may identify yourself or, if you choose, you may remain anonymous. The investigation of a concern is significantly enhanced when callers choose to identify themselves. A few non-U.S. countries, such as France, prefer that callers identify themselves.
The Arch Help-Line is available 24 hours a day, seven days a week. Calls to the Arch Help-Line are answered by trained service representatives at AlertLine®, an independent third-party service. To protect the identity of anonymous callers, the Arch Help-Line service does not use Caller ID, tape record conversations, identify the gender of the caller or use any other method of identification. The Arch Help-Line also provides translation services for individuals who prefer to speak in a language other than English.
If you call the Arch Help-Line, the service representative will listen as you ask questions or describe your concern. A summary of the call will then be forwarded to the Arch Ethics Officer for resolution with the appropriate level of management. Complaints regarding accounting, internal controls or auditing matters and complaints specifically directed to the Board of Directors will be forwarded promptly to the Audit Committee of the Board of Directors for investigation and resolution.
To call the Arch Help-Line:
Anonymous Reports
If you make an anonymous report to the Arch Help-Line, you will be provided with a case number and a date to call back to follow up on the status of your report. When you receive a case number, be sure to use it to call back on your appointed date. Calling back will allow you to receive a status report as well as provide the Company an opportunity to ask additional questions that may be necessary to resolve your concern.
At times it can be extremely difficult to investigate anonymous calls. If your identity is necessary to address your question or concern, you will be advised in advance, if at all possible.
Policy Against Retaliation
If you report a violation or raise an issue or concern, you will be treated with dignity and respect and will not be subject to retaliation, threats or harassment. Any employee who retaliates against another person who has raised an issue, reported a problem or supplied information during an investigation will be subject to discipline up to and including dismissal. This policy applies regardless of the outcome of the investigation.
We expect employees to report issues and concerns in good faith. Any employee who deliberately makes a false accusation with the sole purpose of harming or retaliating against another person will be subject to discipline up to and including dismissal.
If you feel that you or someone you know has been retaliated against for raising an issue or concern, you should contact any of the resources listed in this Code including the Arch Ethics Officer or the Arch Help-Line.
Violations
Most employees will follow our Code of Conduct voluntarily and with commitment. In the event that an employee violates our Code, policies or any of the laws and regulations that govern our business, we will take immediate and appropriate action. Depending on the nature, severity, and frequency of the violation, we will take disciplinary actions including dismissal, claims for reimbursement of losses or damages, and civil prosecution. Discipline will be handled fairly and consistently.
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