2021 Owens Corning Sustainability Report | Expanding Our Social Handprint | Human Rights & Ethics | 282 ■ Open Reporting Process and Internal Investigations Owens Corning works to ensure that all employees are aware of all applicable laws and company policies, including our Code of Conduct. If the need arises for employees to report suspected misconduct, including harassment, discrimination, and other ethical issues, employees can voice their critical concerns through an open reporting process. All employees are encouraged to report suspicions of violations of law or policy, and they are expected to cooperate in the investigation of potential wrongdoing per our Code of Conduct. They can do so without fear of retaliation, which is strictly prohibited by Owens Corning as a way to protect whistleblowers or individuals who raise concerns. No hardship, loss of benefits, nor penalty may be imposed on an employee as punishment for good-faith reporting of suspected misconduct, responding to a concern of suspected misconduct, appearing as a witness in the investigation of a report, serving as an investigator, or otherwise cooperating in a workplace investigation. Retaliation or attempted retaliation is a violation of company policy, and anyone who engages in retaliation may be subject to discipline, up to and including termination. This expectation is reinforced with senior business and HR leadership during a quarterly compliance review. Employees are encouraged to report their concerns to any manager, member of human resources or the law department, or any member of our business conduct council. Employees may also submit their concerns (anonymously, if desired) to our business conduct council through a confidential helpline (1-800-461-9330) or web portal (helpline.owenscorning.com), which are operated by a third-party service provider. Employees can also report their concerns to the business conduct council using a designated email address or a dedicated postal mailbox. Owens Corning takes all reports of misconduct seriously. Any concern brought to the company’s attention is thoroughly reviewed and investigated by the business conduct council as appropriate. We make every effort to ensure that investigations are consistent, comprehensive, and confidential to the greatest extent possible. If a report is substantiated, the company will respond as it deems appropriate or necessary consistent with laws, internal procedures, and best practices, and we will act swiftly to correct the problem and deter future occurrences. Depending on the circumstances, this may include training and/or disciplinary action up to and including termination. Individuals suspected of being in violation of the law may also be subject to civil or criminal prosecution. Significant breaches of our Business Conduct Policies on the part of certain senior executives are escalated to the audit committee of the board of directors. The audit committee would determine the manner of investigation of any such reports and they are disclosed as applicable by law. Internal investigations are reviewed for trends and opportunities at least quarterly and further discussed with senior business leaders. The audit committee receives a periodic report along with an update of the compliance program in general, including any breach of applicable law. Compliance operations will report significant highlights from the open reporting process to all employees annually, which may include the number of reported concerns received, the number of substantiated concerns, the percentage of anonymous reports, and the number of employees who were terminated for such concerns. In 2021, there were no substantiated reports that had an actual or potential material financial impact on the company. The majority of reported concerns reviewed were employee-related matters, with a smaller number of business integrity reports. Fewer than 15% of the reports resulted in a finding of substantiated policy violations. Even if reports were not substantiated, many of them presented opportunities for improvements in management systems. Identified trends led to enterprise-level changes, including policy updates, targeted training, and improved communication. Because no concerns reported in 2021 were critical, no concerns went through our escalation process, nor was the board of directors called upon to respond. ■ Anti-Corruption Owens Corning uses many safeguards to avoid corruption related to our business — including corruption on the part of any of our employees, members of our board of directors, and business partners including third parties and independent agents. This policy is overseen by our audit committee. Our anti-corruption policies align with applicable anti-corruption laws, including but not limited to the U.S. Foreign Corrupt Practices Act of 1977 (FCPA), the UK Bribery Act, and the OECD Convention on Combating Bribery. Specific controls exist within the Owens Corning treasury policies and procedures to review vendors and assess appropriateness before payments are processed. These controls are reviewed regularly by internal audit based on audit scoping. In addition, sensitive transactions, including gifts, travel, and entertainment, are reviewed using business analytics tools, as well as by our third-party business partner, to ensure compliance with Owens Corning policies. Additionally, internal audit performs an annual