The Speak Up Reporting Hotline refers to both the web-portal and phone based communication lines that allow SkyWater employees and other SkyWater stakeholders to report concerns or ask questions anonymously. The Speak Up Reporting Hotline is provided by our third-party vendor, Ethico.

Yes. The Speak Up Reporting Hotline does not attempt to identify reporters whether through calls or the report form online. Reporters have the option to remain anonymous or provide their name and other contact information. Reporters are provided a Report Key that allows for anonymous communication after their initial report with the investigator assigned to their report.

Doing the right thing requires us to speak up when we have questions or concerns about ethical misconduct or potential violations of our Code, policies, or the law.

It is important that you share specific details concerning the matter in order to facilitate a thorough review. Providing partial or incomplete information may result in case closure due to insufficient information. Information needed to complete a thorough review may include:

• First/last name of person(s) or organization(s) engaged in alleged wrongdoing
• Description of the event, location, and date/time of when event occurred
• Specific details or synopsis of the concern(s) being raised
• First/last names of witnesses to the event or others who may have knowledge of the concern(s) being raised
• How the event was discovered if the reporter was not a participant or directly involved
• Supporting documentation if available, including policies, emails, text messages, etc.

Reports made through the Speak Up Reporting Hotline are maintained on the Ethico secure server. Our Ethics and Compliance team processes all incoming reports. Our Senior Vice President of HR and Chief Financial Officer provide oversight of SkyWater’s management of reports made to the Speak Up Reporting Hotline. The Audit Committee of the Board of Directors reviews cases related to accounting, auditing, or financial matters. Cases are assigned to investigators who are trained to handle complex and sensitive matters in a confidential manner.

Each allegation reported through the Speak Up Reporting Hotline is unique, so the estimated time of completion depends on many factors, such as the complexity of the issue, the number of people involved, or the nature and extent of documents or other evidence involved. Reporters may use the Report Key to check on the status of a review or communicate with the lead investigator.

Reporters are provided a Report Key and select a password at the time they submit their report. Select the “Follow-up On A Report” button on our Speak Up Reporting Hotline page and enter your Report Key and Password. Once you have accessed your report, you will be able to ask questions, provide updates, or inquire about the status of the report anonymously.  SkyWater is committed to communicating with reporters about the receipt and status of investigations.

Confidentiality means that investigators and administrators of the Speak Up Reporting Hotline will not disclose information to individuals outside of the reasonable “need to know” standard. This includes information received, used, maintained, or accessed during the course of normal duties, such as case reviews.

Anonymity means that personnel may report any concern through the reporting channels without disclosing their identity. Reports made in good faith will be taken and reviewed without an attempt to identify the reporter.

Be advised that:

• There are circumstances in which confidentiality and anonymity may not be maintained, such as disclosures pursuant to a subpoena or court order, a lawful discovery request, or a disclosure necessary to resolve a potential compliance matter.
• Anonymity applies to an individual’s identity.
  Confidentiality applies to information received, used, maintained or accessed.
• Reporters may choose to release their identity during or after a completed review.
  Information about a reporter’s identity, if provided, will be retained as part of the case record.
• Information shared outside of the Speak Up Reporting Hotline case review process is not protected by the Ethics and Compliance team.
• Information shared through the reporting channels may lead to indirect identification of a reporter given the specific details provided.