Helpline
     
     If employees are unsatisfied with responses to questions regarding ethical conduct guidelines, a further avenue of guidance and reporting is the Company’s Business Conduct and Ethics Officer or through the Helpline. The Helpline is staffed by a third party, and callers will be given the option of being assigned a random number for followup communication instead of revealing their identity. The Company Ethics Helpline can be reached at 1-866-825-5483.
     Employees are encouraged to contact any of the following individuals if they need assistance or guidance on the Code.

     —Their supervisor
     —Any senior management representative
     —Internal Audit
     —Ethics Officer: Jonathan Greenberg 410-628-3244
     —Ethics Director: Jean Marie Padden 410-628-8448

Frequently Asked Compliance Questions
     
     Question 1: What is the Company Helpline?
     Answer 1: If for any reason you are unable or unwilling to report a compliance concern to your immediate supervisor or any level of management, the Helpline is a means for you to anonymously report your concern beyond traditional reporting mechanisms.

     Question 2: What type of compliance concerns might I report?
     Answer 2: Examples of compliance concerns are as follows:
Quality or Testing issues, Improper Use of Business Resources, Conflict of Interest, Theft, Falsifying Records/Information, Billing Accuracy, Sexual Harassment,

     Question 3: Is the Helpline really anonymous?
     Answer 3: Yes, the Helpline is really anonymous. It is managed by an outside company, which forwards a confidential report of the call to the Ethics Officer of the Company for investigation. The caller is given a number to call back to obtain the status/results of the inquiry. The caller’s identity is protected, except as disclosure required by law (for example, a report of a pending threat might require the Helpline to make a police report to protect life or property.)

     Question 4: Who is responsible for investigating the Helpline calls?
     Answer 4: The Code of Business Conduct and Ethics names the Ethics Officer as the General Counsel of the companies. This Officer is responsible for the investigation of reports. At UIC and its subsidiary companies, Jonathan Greenberg, the General Counsel, is the Chief Compliance Officer.
     
     Question 5: What happens when the Audit Services & Corporate Responsibility Department receives a report of a call from the outside company?
     Answer 5: In order to ensure that issues are addressed and resolved in a consistent manner, Audit Services maintains a standard process for addressing and resolving such issues. The resolution process generally includes the following: an appropriate investigation based on the allegations; a determination of actual misconduct, if any; the implementation of corrective actions, including any obligatory disclosures; the implementation of preventive actions to minimize the chance of reoccurrence; and the implementation of follow-up actions, monitoring and management controls.

     Question 6: Who is responsible for carrying out the corrective and preventive actions?
     Answer 6: Management is responsible for carrying out the corrective and preventive actions in a reasonable and timely manner. Management is accountable to the Corporate Responsibility Officer to provide information demonstrating compliance relative to the particular law, regulation, standard, or policy in question.

     The Helpline is available Toll Free 24 Hours per Day, 7 Days per Week at 1-866-825-5483.

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