Ethics Policy

Building an Ethical Workplace Together

ETHICS HOTLINE POLICY

SCOPE:
This policy applies to all Jacksonville Aviation Authority (JAA) employees, including part time, temporary, and contract employees.

PURPOSE:
Jacksonville Aviation Authority is committed to the highest possible standards of ethical, moral and legal business conduct. In line with this commitment and JAA's commitment to open communication, this policy aims to provide an avenue for employees to raise concerns and reassurance that they will be protected from reprisals or victimization for whistleblowing in good faith.

POLICY:
The Ethics Hotline Policy is intended to cover serious concerns that could have a large impact on JAA, such as actions that:
• May lead to incorrect financial reporting;
• Are unlawful;
• Are not in line with company policy, including the Ethics Values/Code of Conduct; or
• Otherwise amount to serious improper conduct.
Regular business matters that that do not require anonymity should be directed to the employee's supervisor and are not addressed by this policy.

SAFEGUARDS:
Harassment or victimization of the complainant will not be tolerated.

Confidentiality
Every effort will be made to protect the complainant's identity. Please note that the information provided by you may be the basis of an internal and/or external investigation into the issue you are reporting and your anonymity will be protected to the extent possible. However, your identity (if known) may become known during the course of the investigation.

Anonymous Allegations
The policy allows employees to remain anonymous at their option. Concerns expressed anonymously will be investigated, but consideration will be given to:
•The seriousness of the issue raised;
•The credibility of the concern; and
•The likelihood of confirming the allegation from reliable sources.

Malicious Allegations
Malicious allegations may result in disciplinary action.

 

PROCEDURE:
Reporting
The Ethics Hotline procedure is intended to be used for serious and sensitive issues. Serious concerns relating to financial reporting, unethical or illegal conduct should be reported in either of the following ways:
•Through the Toll Free Hotline: 877-472-2110
•Fax alternative for written documents: 215-689-3885
•E-mail: reports@lighthouse-services.com
•Web: lighthouse-services.com (click on Report Incident link). Username: JAA and Password: airport1
•Intranet: www.lighthouse-services.com/jaa

Callers to the Hotline will have the ability to remain anonymous if they choose. Please note that the information provided by you may be the basis of an internal and/or external investigation into the issue you are reporting and your anonymity will be protected to the extent possible by law. However, your identity (if known) may become known during the course of the investigation. Complaints are submitted by Lighthouse to JAA or its designee, and may or may not be investigated at the sole discretion of JAA.

Employment-related concerns should continue to be reported through your normal channels such as your supervisor, or to the Ethics Officer (904-741-3632) or Senior Manager of Employee Relations (904-741-2268).

Timing
The earlier a concern is expressed, the easier it is to take action.

Evidence
Although the employee is not expected to prove the truth of an allegation, the employee needs to demonstrate to the person contacted that there are sufficient grounds for concern.

HOW THE COMPLAINT WILL BE HANDLED:
The action taken will depend on the nature of the concern. The Audit Committee of JAA Board of Directors receives a report on each complaint and a follow-up report on actions taken.

Initial Inquiries
Initial inquiries will be made to determine whether an investigation is appropriate, and the form that it should take. Some concerns may be resolved by agreed action without the need for investigation.

Report to Complainant
Whether reported to JAA personnel or through the hotline, the complainant will be given the opportunity to receive follow-up on their concern:
•Acknowledging that the concern was received;
•Indicating how the matter will be dealt with;
•Giving an estimate of the time that it will take for a final response;
•Telling them whether initial inquiries have been made;
•Telling them whether further investigations will follow, and if not, why not.

Further Information
The amount of contact between the complainant and the body investigating the concern will depend on the nature of the issue, the clarity of information provided, and whether the complainant remains accessible for follow-up. Further information may be sought from the complainant.

Information
Subject to legal constraints the complainant will receive information about the outcome of any investigations.

JAA reserves the right to modify or amend this policy at any time as it may deem necessary.