1. What is the Warburg Pincus Helpline?
The Helpline is an internet- and telephone-based reporting tool operated by an independent third party (Convercent) that allows employees and third parties to confidentially and anonymously (subject to local law) ask questions and report potential concerns about actual or suspected misconduct.
2. Why has Warburg Pincus arranged for the Helpline to be available, and what are its benefits?
Warburg Pincus is committed to conducting business with integrity. To execute on its commitment, Warburg Pincus relies on its employees and third parties to adhere to the Company’s policies, values and mission, raise questions, and report potential concerns. Employees and third parties should feel: (i) confident and secure about internally raising a question or potential concern in good faith; and (ii) that Warburg Pincus will take their questions and potential concerns seriously. In addition, the Helpline allows Warburg Pincus to foster and continually enhance our culture of compliance, and take steps to mitigate risks that could impact our investments, investors, or reputation.
3. Should I raise my question or potential concern through the Helpline, or through my manager or human resources representative?
You may raise your question or potential concern through any channel that you choose, including directly to your manager, your manager’s supervisor, another individual in your department, Compliance, or Legal. You may also raise your question or potential concern through the Helpline, especially if you are uncomfortable approaching a manager or other individual directly, wish to remain anonymous, or have concerns that a previously reported issue is not being adequately addressed. The Helpline is accessible both online and by phone.
4. What type of situations should I report?
The Helpline is intended for employees and third parties of Warburg Pincus and its portfolio companies to raise questions about or report any suspected, alleged or actual violations of law, the Warburg Pincus Code of Ethics, and Company policies, including the Company’s Compliance Policies and Procedures Manual. If you become aware of any potential or actual violation of law or Company policy, you should report it, even if you have not witnessed the potential violations firsthand.
5. Should I identify myself? May I ask my question or report my potential concern anonymously, and how can I check on the status of what I have reported?
In general, you may, but are not required to, identify yourself when submitting a question or reporting a potential concern through the Helpline. Once you submit a question or report through the Helpline, you will receive an access code, which is required to return to your previous submission. This process allows you to supplement your report with additional details, and communicate with the Company, including answering any of the Company’s follow-up questions, while protecting your anonymity (where permitted by law).
Please note that some countries and localities, however, prohibit anonymous reporting. Regardless of whether you report anonymously, Warburg Pincus will make every reasonable effort to hold your information in confidence and strictly prohibits any form of retaliation—direct or indirect—against anyone who asks a question or reports a potential concern in good faith, or participates in an investigation or its resulting remediation in any way.
6. How does the Helpline maintain confidentiality?
The Helpline does not record or trace phone calls, use caller identification, or generate or maintain internal connection logs containing Internet Protocol (IP) addresses. Consequently, no information linking your computer to Helpline is subsequently available to the Helpline operator or the Company.
7. After I submit a report, who can access it?
Incoming reports are memorialized by Convercent employees directly on the Helpline’s secure server and then automatically routed to designated individuals within the Company. Access to the reports is only available to the specific individuals within the Company who are responsible for reviewing the report and identify next steps.
8. How does Warburg Pincus review questions and potential concerns?
The Company reviews all questions and potential concerns consistent with an established process developed with outside counsel in view of regulator guidance and industry best practices.
Once a report is received, the Compliance and/or Legal teams within the Company will conduct an initial assessment of the question / potential concern to determine how to proceed. Based on this initial assessment, Compliance and/or Legal will determine how to proceed (e.g., seeking additional information from the reporter; referring the question / potential concern to another function or group for review and resolution; identifying and/or evaluating whether the report identifies a potential violation of law or Company policy that requires immediate or interim corrective actions).
9. What if this is an emergency?
Concerns about an immediate threat of physical harm or damage to property should not be reported through the Helpline. If you require emergency assistance, please contact your local emergency services and, to the extent possible, a Company manager.
10. What if I encounter retaliation in response to asking a question or making a report?
In accordance with Company policy, Warburg Pincus strictly prohibits any form of retaliation—direct or indirect—against anyone who asks a question or reports a potential concern in good faith, or in any way participates in an investigation or its resulting remediation.
If you believe you have faced retaliation of any kind, please report it to Compliance or Legal immediately.