Compliance Helpline

Syntrio is a unique confidential communication and reporting system, referred to internally as the SHINE-11 Compliance Helpline, that is designed to make it as convenient as possible for employees, partners or the public to send concerns, questions, and comments directly to SHINE’s Compliance Officer, the SHINE Board of Directors or SHINE’s General Counsel on a confidential basis.

We believe that our Stakeholders are our most important asset. By creating open channels of communication, we can promote a positive work culture, maintain a safe workplace for our employees and ensure the protection of the natural environment.

Publicly traded companies are required by law to have an anonymous reporting vehicle to address accounting, auditing and internal controls fraud directly to the audit committee. SHINE currently is a private employer but prides itself in following these regulations. An effective helpline system will enhance our other efforts to foster a culture of integrity and ethical decision-making.

To receive a response from management, and if you called the Compliance Helpline, call back at
+1-833-SHINE-11 (+1-833-744-6311) after five business days and have your case number ready. To check for a response you left on the website or to leave an additional message, visit www.InTouchWebsite.com/SHINE-11 and enter your case number and password. The case numbers for the phone helpline and website are different, so you will need to follow up using the same system you used to report the concern.

Yes. With Syntrio, you have the ability to file a confidential, anonymous report via telephone, an email or the web.

Any violation of SHINE’s policies and procedures, including the SHINE Code of Conduct, or even applicable laws, regulations and industry codes. Additionally, any items that are safety-related, whether they are nuclear, radiation, industrial, or any other designation.

Certainly! SHINE is a socially and environmentally responsible leader. We want anyone interacting with SHINE to have an avenue to voice their concerns.

You are encouraged to speak up if you become aware of a potential violation of SHINE’s Code of Conduct or the law. If you’re a SHINE employee, ideally, you will bring any concerns directly to your immediate supervisor, or other member of our management team. We recognize, however, that there may be circumstances when you’re not comfortable reporting an issue in this manner. It is for such circumstances that we have partnered with Syntrio. We would rather you report anonymously than keep the information to yourself. If you require further guidance regarding the Helpline and reporting your concern, please contact us at www.InTouchWebsite.com/SHINE-11 or compliance@shinefusion.com.

We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting the right people know if someone is not acting appropriately. If you are a SHINE employee, you are obligated to report potential issues in accordance with the SHINE Code of Conduct. By working together, we can maintain a healthy and productive environment.

We certainly do. In fact, we need you to report. You know what is going on at SHINE—both good and bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact to SHINE and our community. Also, offering positive input may help identify issues that can improve our corporate culture, safety culture and performance.

Reports are entered directly on the Syntrio secure server to prevent any possible breach in security. Syntrio makes these reports available only to specific individuals within SHINE who are charged with evaluating and investigating each report. Each of these report recipients has had training in keeping these reports in the utmost confidence.

SHINE has an internally hosted and managed email account to accept confidential messages from individuals who do not wish to submit their concern through the Syntrio helpline. Please send your concern to compliance@shinefusion.com and a member of the Compliance team will respond to your message within 1 business day.

The Company is committed to investigating all reported concerns, where appropriate, to the extent possible. Depending upon the type of concern, either SHINE’s Compliance Officer, the SHINE Board of Directors or SHINE’s General Counsel will expeditiously and confidentially investigate concerns brought to the Company’s attention. As appropriate, the members of this group may confidentially engage other functions within the Company or outside firms to assist with an investigation.

When you file a report at the Syntrio website or through the SHINE-11 Helpline, you receive a unique case number. You can return to the Syntrio system again either through the web or by telephone and access your original report to add more detail or answer questions posed by the Company. We strongly suggest that you return to the Helpline in the time specified to answer Company questions. Once this happens, you and the Company have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

All Syntrio correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

For general inquiries please contact us via email at compliance@shinefusion.com.

To ensure the confidentiality of reports submitted to the Helpline, Syntrio is unable to provide a reporter with a lost case number. If this happens and you have additional information to provide, please submit a new report and indicate that it is in follow-up to a previously reported concern.

Syntrio does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to Syntrio is available. In fact, Syntrio is contractually committed not to pursue a reporter’s identity.

If you feel uncomfortable making a report on your work computer, you have the option of using a computer outside our work environment (such as one located at a public library, at a friend’s house, etc.) through the Syntrio secure website (www.InTouchWebsite.com/SHINE-11).

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. The Syntrio system strips away internet addresses so that anonymity is totally maintained. Plus, Syntrio is contractually committed not to pursue a reporter’s identity.

The Syntrio system is designed to protect your anonymity. However, if you wish to remain anonymous, you—as a reporting party—need to ensure that the body of the report does not reveal your identity by accident. For example, “From my work area next to Jill Jones…” or “In my 6 years…”.

Yes. You will be asked to provide the same information that you would provide in an web-based report and an interviewer from Syntrio will type your responses into the Syntrio website. These reports have the same security and confidentiality measures applied to them during delivery.

There is a section in the report for identifying yourself, if you wish.

SHINE has a strict non-retaliation policy that protects those who report a concern in good faith. Furthermore, you may submit your concern anonymously, where allowable by local laws, via Syntrio. If you feel you have been subject to retaliation for reporting a concern, please immediately contact compliance@shinefusion.com.

All unethical conduct, at any level, ultimately hurts the Company and all stakeholders, including you. So, if you know of any violations of Company policy or unethical conduct, consider it your duty to yourself and your colleagues to report it.

File a report. Syntrio can help you prepare and file your report so it can be properly understood. The Company would rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you weren’t sure.

The Syntrio system and report distribution are designed so that implicated parties are not notified or granted access to reports in which they have been named. The SHINE-11 Compliance Helpline is managed by the Corporate Compliance team, which includes SHINE Board members and/or General Counsel.

No. Any reported concern regarding the SHINE Compliance Officer will be reported directly to a SHINE Board member and/or General Counsel. The Compliance Officer will not be contacted directly during an initial complaint. The Compliance Officer may be contacted during an investigation only.