The purposes of this policy are to (i) promote compliance with the laws, rules, and regulations that govern Mobileye B.V. (the “Company”) business operations; (ii) communicate the reporting channels the Company has established for employees and others to report possible violations of the law, the Intel Code of Conduct (the “Code”), and other Company policies and guidelines; and (iii) reinforce Company policy prohibiting retaliation against anyone who reports a concern in good faith.
To help our Company conduct business with uncompromising integrity and professionalism, every employee has an obligation to report possible violations of the law, the Code, and other Company policies and guidelines. Managers and employees who learn of a possible violation of law, regulation, or legal policy, including any concern relating to sourcing of conflict minerals, must immediately report that concern to Legal.
I. REPORTING RESOURCES
The Company has many ways for employees and others to ask questions or report concerns:
- You can ask questions and report concerns to any manager, including your direct manager, a department head, a division general manager, or any another manager;
- You can ask questions or report concerns with Company groups that specialize in handling such issues, including Human Resources, Legal, or Information Security;
- You can email concerns relating to Company legal policy to GeneralCounsel@mobileye.com; and
- You can report an ethics or compliance or safety concern online or by phone through the Intel Ethics and Compliance Reporting Portal, which is hosted by a third party and allows anonymous reporting where permitted by
Employees do not need to be certain about a concern, have evidence of misconduct, or even know that a violation of policy or law has occurred to report. No matter how a concern is raised, all reports are taken seriously. A team will promptly review the matter and determine what actions are appropriate based on the findings consistent with applicable law and other applicable guidelines.
The Company will follow the laws applicable to employees located in the European Economic Area.
Employees are required to cooperate fully with internal investigations and employees who fail to do so are subject to disciplinary action up to and including termination of employment, in accordance with applicable local laws. For investigations into alleged violations of the U.S. National Labor Relations Act, an employee’s participation, while strongly encouraged, is voluntary.
II. POLICY PROHIBITING UNLAWFUL RETALIATION OR DISCRIMINATION
The Company does not tolerate retaliation against anyone who in good faith reports possible violations of law, the Code, or other company policies or procedures, questions on-going or proposed conduct, or participates in an internal investigation. However, individuals who report concerns or provide evidence in bad faith that they know to be false or without a reasonable belief in the truth and accuracy of such information, will not be protected by this policy and may be subject to disciplinary action, up to and including termination.
In accordance with applicable law, the Company will not discharge, demote, suspend, threaten or harass directly or indirectly, or in any other manner discriminate or take retaliatory action against, any individual based upon any lawful actions of such individual with respect to reporting a concern in good faith internally through the available Company resources or externally to any regulatory agency.
Employees who retaliate or attempt to retaliate against anyone who reports a concern in good faith or participates in an internal investigation are subject to discipline up to and including termination. Employees who believe they have experienced retaliation should contact HR Legal immediately.
III. PUBLICATION ONWEBSITE
This Whistleblower Policy will be published on the Company’s website: www.mobileye.com.
Questions or concerns regarding this Policy can be sent to the General Counsel (contact information available on the Company intranet).
V. EFFECTIVE DATE
This Policy shall take effect on December 11, 2017.