Speak Up is a two-way communications channel for employees that offers them the opportunity to ask questions, voice concerns, make recommendations, or complain, on any of IBM's operations and policies--and remain anonymous.

It also offers management the opportunity to explain or resolve employee concerns, communicate with employees, and explain management actions.

IBM management provides responses to Speak Ups while corporate communications determines how the program operates. Speak Up administrators direct the program at site, division and group locations. The key aspects of Speak Up are:

1. SUBMITTING A SPEAK UP

a. Any IBM employee or retiree may submit a Speak Up.

b. Speak Up forms can be obtained at most bulletin board locations. However, a Speak Up form is not mandatory. Any envelope marked "Speak Up" will be delivered to a Speak Up administrator.

c. Speak Ups are opened only by Speak Up administrators. If an unmarked envelope contains a letter stating it is a Speak Up, the letter should be forwarded to a Speak Up administrator in an IBM Confidential envelope marked "To Be Opened By Addressee Only." No copies of the letter should be made for the files.

2. PROCESSING A SPEAK UP

a. When a Speak Up is received, the administrator removes the name, address, and any identifying information. No one but a Speak Up administrator knows the identity of a Speak Up writer. The administrator will not provide the name of an employee using the program.

b. Administrators assign Speak Ups to the manager responsible for the subject written about. The manager should generally answer in writing within four working days. The reply must respond to all issues raised in the Speak Up.

c. An employee can request an interview, and an interviewer should be ready to talk with the employee by telephone or in person within four working days. Interviews cannot be initiated by managers unless there is a clear benefit to the employee and a Speak Up administrator concurs. An employee can remain anonymous in a telephone interview by identifying him/herself by a number assigned to each Speak Up. No attempt to discover an employee's identity must be made during an interview. A follow-up letter addressed to "Dear IBMer" and a written interview report to the administrator are required after a Speak Up interview.

d. A Speak Up administrator determines whether a reply responds to all the issues raised and whether it is clear and straight forward. The administrator then personally mails the response to the employee at home, avoiding the internal mail system.

3. INVESTIGATING A SPEAK UP

a. If the recipient of a Speak Up does not investigate the issue personally, he or she should assign it to a person who is not involved in the circumstances covered in the Speak Up.

b. Speak up investigations should be completed with as little visibility as possible. Management of an area being investigated should not be informed the investigation is being conducted as a result of a Speak Up unless absolutely necessary.

c. The manager receiving the Speak Up is responsible for the content and timeliness of the reply even if he or she did not personally conduct the investigation.

d. Since Speak Up responses are unclassified documents and are mailed to employees homes, care must be exercised in creating the content of these letters.

e. When a Speak Up investigation determines action should be taken, the Speak Up administrator must be informed of this. The Speak Up writer must also receive as much information regarding the proposed action as can be reasonably communicated. The person responsible for any action should be identified along with the date the activity is to be completed. When the responding manager is told the action has been completed, the Speak Up administrator should also be notified.

4. HANDLING SPEAK UPS FROM OTHERS

a. Persons not eligible to participate in the Speak Up program (non-employees: i.e., spouse on behalf of employee, contractors) will be told by the Speak Up administrator that the program is available to employees only. An offer can be made by the administrator to forward the letter to an appropriate person in IBM, but it will be treated as an open letter to the corporation not bound by the guidelines of the Speak Up program.

b. Third-party appeals (one employee on behalf of or representing another) should be acknowledged, but the person making the appeal must be told the issue cannot be addressed unless the affected employee brings the issue forward.

c. Unsigned Speak Ups will be investigated only if the Speak Up administrator deems it appropriate.

5. RETAINING SPEAK UP MATERIAL

To protect the anonymity and privacy of employees using Speak Ups, the following retention procedures have been established for Speak Up files:

a. The manager to whom a Speak Up is assigned must retain the investigation documents and associated material for one year. Speak Up administrators also keep files for the current year plus the previous year. After this retention period, the files are destroyed.

b. The investigator of a Speak Up (if different than the signing manager) may retain material for a period not to exceed 90 days. This should allow for any necessary follow-up activity. At the conclusion of the 90-day period, the investigator's file must be consolidated with the manager's file above.

c. There should be no further retention of information related to Speak Up investigations than specified above.