EPAM Systems, Inc. (“EPAM”) has set up the EPAM EthicsLine to enable you to raise questions about or report any suspected violations of EPAM’s Code of Ethical Conduct, its policies, or laws and regulations (an "EthicsLine Report").
The purpose of this Data Privacy Notice is to inform you about the collection, processing and use of personal information related to EthicsLine Reports. We process this personal information in order to comply with our legal obligations to detect wrongdoing in the workplace and/or because it is in our legitimate interest to do so.
EPAM runs both the EthicsLine online portal and a phone system, and has implemented controls to limit distribution and provide for confidentiality and anonymity as far as appropriate, while at the same time weighing those interests against relevant laws and the need to conduct a fair, complete and compliant review.
When you submit an EthicsLine Report via the EthicsLine it will be automatically routed to EPAM’s Chief Compliance Officer located in the United States, including any personal information contained within it. EPAM will make every reasonable effort to keep reported information confidential and communicated on a need-to-know basis only to those with a legitimate business or legal need.
EPAM will not discipline, discriminate, retaliate or tolerate retaliation against a person because he or she submitted an EthicsLine Report which turns out to lack merit, provided it was made honestly and in good faith.