Policies
Whistleblower Policy
Scope
This Policy applies to all employees.
Purpose
To encourage employees to:
1. Report promptly and in good faith any suspected financial improprieties or irregularities, violation of the Code of Ethics and Business Conduct or other Company policies, and legal.
2. Report promptly and in good faith any suspected financial improprieties or irregularities, violation of the Code of Ethics and Business Conduct or other Company policies, and legal.
Financial Issues
▪ Fraud or deliberate error in the preparation, evaluation, review or audit of any financial statement or other financial report of the Company.
▪ Fraud or deliberate error in the recording and maintaining of financial records of the Company.
▪ Deficiencies or noncompliance with the Company’s internal accounting controls or policies.
▪ Misrepresentation or false statement to or by a senior officer or accountant regarding a matter
contained in the financial records, financial statements, or other financial reports of the
Company.
▪ Deviation from full and fair reporting of the Company’s financial condition.
Other Areas to Report
▪ Activities that are not in line with the Code of Ethics and Business Conduct, such as fraud, anti-trust, conflict of interest, theft, and bribery.
▪ Conduct that may violate an applicable law or regulation.
▪ Violation of a Company policy.
Non-Retaliation
No officer, director, employee or agent of the Company shall take any harmful action with the intent to retaliate against any employee, including but not limited to any action negatively impacting their employment or any form of harassment, due to the employee’s good faith reporting of suspected misconduct or violation of an applicable law, regulation or Company policy or due to the employee providing assistance in an investigation by the Company or a governmental agency.
Good Faith Reporting: A good faith report may not necessarily lead to a conclusion that there was inappropriate or unlawful conduct. A good faith report is made when the employee believes that there may be activity about which the Company should be aware or should investigate. A report that the employee knows is false is not a good faith report.
Reporting Options
Employees are encouraged to raise issues to their manager, whenever possible. This is the easiest and fastest way to resolve issues. If the employee does not feel comfortable discussing a concern with their manager, the manager is part of the issue, or the employee believes that the concern was not addressed appropriately, the employee can also use any of the following options:
1. Contact another manager that the employee trusts
2. Contact Human Resources.
Investigation and Confidentiality
The Company will promptly and thoroughly investigate all complaints or concerns communicated under this Policy. To the extent possible, the Company will maintain the anonymity of employees who choose to provide their identity. However, to appropriately respond to a concern, the Company may need to interview other employees or individuals associated with the Company.
Consequences
Any manager that retaliates against an employee under this Policy or who condones illegal or unethical behavior will be subject to disciplinary action up to and including termination.
Any manager or employee who is aware of, or suspects, unlawful or unethical conduct by another employee or a manager of the Company and fails to report it will be subject to disciplinary action up to and including, termination.
Any employee who brings forth a complaint or concern that is not in good faith, or that the employee knows, or suspects is false, will be subject to disciplinary action up to and including, termination.