FairPoint Communications 2010 Annual Report Download - page 175

anticipate every situation that will arise, you should keep in mind the following steps as you consider a particular problem or concern.
(a) Make sure you have all the facts. In order to reach the right solutions, we must be as fully informed as possible.
(b) Ask yourself: What specifically am I being asked to do or ignore? Does it seem illegal, unethical or improper? This will enable you to focus on the
specific question you are faced with, and the alternatives you have. Use your judgment and common sense; if something seems unethical or improper, it may
very well be.
(c) Clarify your responsibility and role. In most situations, there is shared responsibility. Are your colleagues informed? It may help to get others
involved and discuss your concerns.
(d) You should report violations of this Code to or otherwise discuss your concerns in this regard with your supervisor or your Human Resources
business partner, any member of the Legal Department or anonymously through the EthicsPoint Hotline at 866.294.9318. In many cases, your supervisor
will be more knowledgeable about the question or concern, and will appreciate being brought into the decision-making process. Remember that it is your
supervisor’s responsibility to help solve problems. Supervisors and Human Resources business partners are obligated to report violations of this Code to the
General Counsel.
(e) In the case where it may not be appropriate to report a violation to or discuss your concerns with your supervisor or your Human Resources business
partner, or where you do not feel comfortable approaching your supervisor to report a violation or discuss your concerns, you may report the violation or
discuss your concerns with the General Counsel or any member of the Legal Department. If you prefer to report violations or your concerns in writing, on an
anonymous basis, please address your concerns to our General Counsel at the following address: FairPoint Communications, Inc., 521 East Morehead Street,
Suite 500, Charlotte, NC 28202, Attention: Shirley J. Linn.
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(g) Reports of violations of this Code or other complaints made to the EthicsPoint Hotline or to the persons referenced above will be reviewed by the
General Counsel or her designee, who shall either (i) conduct an investigation of the facts and circumstances as she deems appropriate and report her
conclusions and remedial actions taken, if any, to the Audit Committee or (ii) report the alleged violation or other complaint to the Audit Committee for further
direction. The Chairperson of the Audit Committee will also receive all EthicsPoint Hotline reports directly from EthicsPoint.
(h) Your communications of violations or concerns will be kept confidential to the extent feasible and appropriate, and except as required by law.