Data Protection & Privacy Notice
The data privacy regulations of some countries require that a person making a report containing personal data must be notified of certain collection and retention practices regarding the information submitted by that person.
You are being asked to read and acknowledge the terms contained below.
- General
- Use of the Hexion Hotline
- What personal data and information is collected and processed?
- How will the personal data and information be processed after your report and who may access personal data and information?
- Accessing information concerning the report
- Special country regulations
The Hexion Hotline is a web and phone-based intake system provided by Hexion Inc. (“Hexion”) for the reporting of suspected violations of laws or regulations, our Code of Conduct or company policies. You may contact the Hexion Hotline anonymously from most locations subject to local regulations. Hexion does not tolerate reprisal or retaliation against those who report concerns in good faith.
The Hexion Hotline may also be used to report suspected violations of other matters subject to local regulations and requirements.
The Hexion Hotline and the database in which the personal data and information that you may report is stored, are operated by NAVEX Global, Inc. (“NAVEX”) in the United States.
You may contact Hexion's Compliance Officer at globalcompliance@hexion.com with any questions relating to this Notice or the Hexion Hotline.
To proceed further, you are asked to read this notice in its entirety and check the I Acknowledge box that follows.
Use of the Hexion Hotline is entirely voluntary. You are encouraged to report possible violations directly to your supervisor or manager, or to a representative of the Human Resources, Legal or Corporate Compliance Departments, depending on the nature of the possible violation. If you feel that you are unable to do so, you may use the Hexion Hotline to make your report.
The Hexion Hotline is a confidential online reporting system that allows you to make Hexion aware of suspected violations of law or company policies, as well as other concerns you may have. If your concern pertains to a matter that, under local law, may not be accepted by Hexion through the Hexion Hotline, you will need to contact your supervisor or local management or a representative of the Human Resources, Legal or Corporate Compliance Departments to report the matter.
By submitting a report or question to the Hexion Hotline, your personal data will be processed. The legal ground for the processing of your personal data is "Legitimate Interest." In order to properly document and follow up on grievances and claims, personal data related to the conduct of ethical and disciplinary investigations will have to be processed.
Please be aware that the information you supply about yourself, your colleagues, or any aspect of the company’s operations may result in decisions that affect others. Therefore, our expectation is that you only provide information that you believe is true. You will not be subject to retaliation or discipline from Hexion for any report of a suspected violation that is made in good faith, even if it later turns out to be factually incorrect. Please be aware, however, that knowingly providing false or misleading information will not be tolerated and could lead to discipline, up to and including termination of employment. The information you submit will be treated confidentially except in cases where this is not possible because of legal requirements or investigative necessity, in which case the information will be handled sensitively. We encourage you to identify yourself in order for us to follow up with questions we may have.
The Hexion Hotline captures the following personal data and information that you provide when you make a report: (i) your name and contact details (unless you report anonymously) and whether you are employed by Hexion; (ii) the name and other personal data of the persons you name in your report if you provide such information (i.e., description of functions and contact details); and (iii) a description of the alleged misconduct as well as a description of the circumstances of the incident. Note that regardless of whether you identify yourself or report anonymously, your personal information will be treated confidentially and will only be disclosed as set out below.
The personal data and information you provide will be stored in a database which is located on servers hosted and operated by NAVEX in the United States. NAVEX has entered into contractual commitments with Hexion to secure the information you provide in accordance with applicable law. NAVEX is committed to maintaining stringent privacy and security practices including those related to notice, choice, onward transfer, security, data integrity, access, and enforcement.
For the purpose of processing and investigating your report and subject to the provisions of local law, the personal data and information you provide may be accessed, processed and used by the relevant personnel of Hexion, including Human Resources, Finance, Internal Audit, Legal, Corporate Compliance, management, external advisors (e.g. legal advisors), or, in limited circumstances, by technical staff at NAVEX. Those individuals may be located in the United States or elsewhere.
Personal data and information you provide may also be disclosed to the police and/or other enforcement or regulatory authorities. The relevant bodies that receive and process personal data can be located in the United States or in another country that may not provide the level of data protection available in the European Union.
Depending on exceptions that may apply under local or regional data protection law, the personal data you provide will be kept as long as necessary to process your report, or, if applicable, as long as necessary to initiate sanctions or to meet our legal or financial needs.
Where required, Hexion will promptly notify any person who is the subject of a report to the Hexion Hotline except where notice needs to be delayed to ensure the integrity of the investigation and preservation of relevant information.
Where required, the subject of the report may access information concerning the report (with the exception of the identity of the reporter) and request correction of personal data that is inaccurate or incomplete in accordance with applicable law. Similarly, where required, reporters may also access information about the report and request corrections of their personal data in accordance with applicable law. To make any such corrections, please contact Hexion's Compliance Officer at globalcompliance@hexion.com.
Any issues or concerns relating to topics not permitted by law to be reported via the Hexion Hotline should be reported directly to your Manager or Supervisor or a representative of the Human Resources, Legal or Corporate Compliance Departments as appropriate for the subject matter of the possible violation.