General Statement of Purpose
Herman Miller, Inc. (the "Company") and its controlled subsidiaries (collectively “Herman Miller”) are committed to fostering a workplace conducive to open communication regarding the Company's business practices. The Company encourages employees to discuss concerns with their supervisors, who can often be an excellent resource regarding concerns. As employees may not always feel comfortable raising concerns to a supervisor, the Company provides alternate means of reporting concerns as described below.
Whether an employee raises issues with a supervisor or through another channel, the Company is committed to protecting employees from unlawful retaliation and discrimination if they properly disclose or report potentially illegal or unethical conduct or unsafe or unhealthy working conditions in good faith. In an effort to further these commitments, this policy:
- Establishes guidance for the receipt, retention, and treatment of verbal or written reports received by the Company regarding potential violations of the Company’s Code of Conduct, violations of applicable laws, fraud, accounting and auditing matters, unsafe or unhealthy working conditions, and unethical business practices, whether submitted by Company employees or third parties ("Reports");
- Establishes guidance for providing a means to make Reports in a confidential and anonymous manner; and
- Makes clear the Company's intention to discipline, up to and including termination of employment, any person determined to have engaged in retaliatory behavior.
Receipt of Concerns
The Company recognizes that employees may not always feel comfortable raising concerns to a supervisor. There are other ways employees and third parties may express concerns and make Reports. Reports may be made to:
- Navex Global, an independent company engaged to administer the Company's Ethics and Compliance Hotline. Click here for an up-to-date list of telephone numbers by country.
- Navex Global’s confidential, Web-based Internet reporting tool;
- The Director of the Business Risk Group at firstname.lastname@example.org; or
- The General Counsel at email@example.com.
Any Report, whether received by Navex Global or by a Company officer, director, or employee should be immediately forwarded to the Director of the Business Risk Group and the SVP Global Compliance and Employee Relations (part of General Counsel’s office). Reports may be made by phone or in writing and may be made anonymously. Any reports relating to financial controls or fraud will be forwarded to the Audit Committee Chair by General Counsel.
The Company has designated the Director of the Business Risk Group and/or the SVP Global Compliance and Employee Relations, as appropriate, to coordinate any necessary Company action in response to a Report. The Company’s Global Investigations Policy will govern any investigations into allegations of misconduct or wrongdoing.
Reports filed under this policy will be controlled and documented by the Director of the Business Risk Group or the General Counsel’s office, and all related documentation shall be maintained for six years. All related documentation shall be maintained in secured files to which only Navex Global, the Director of the Business Risk Group, the Audit Committee members, and counsel shall have full access.
Treatment of Reports
As noted above, Reports may be made anonymously. All Reports will be taken seriously and addressed promptly, discreetly, and professionally. Discussions and documentation regarding Reports will be kept in strict confidence to the extent possible and consistent with the Company’s commitment to take appropriate action. Should the person submitting the Report identify himself or herself, the recipient of the Report will communicate to the employee the steps to be taken to address the Report, and the person will receive information allowing further comment and follow up regarding the Report.
Retaliation of any kind against any employee that files a Report or voices a concern in good faith under this policy is strictly prohibited. Employees determined to have engaged in retaliatory behavior may be subject to discipline, which could include termination of employment. Any employee who feels that he or she has been subjected to any behavior that violates this policy should immediately report such behavior to his or her supervisor or using the channels described above.
Audit Committee Review of Reports
A summary of reports received under this policy will be communicated to the Audit Committee on a quarterly basis (or a more frequent basis should conditions warrant more timely action).