Whistleblower Protection Policy
1. EFFECTIVE DATE.
3. REPORTING VIOLATIONS.
To report suspected violations, please write, email, or call one of the following resources:
- (a) Compliance Officers. Compliance officers are individuals who are responsible for reviewing and investigating reported violations.
has appointed the following associates to serve as compliance officers. Suspected violations can be reported to one of the following compliance officers:
; . (ii) ; . (iii) .
(b) Anonymous Hotline. has created an anonymous hotline that allows individuals to report a suspected violation. If you want to use this service, please contact the hotline at . (b) (c)Alternative Reporting Options. If you feel uncomfortable reporting suspected violations to one of the compliance officers, or feel that your report has not been addressed properly, contact the human resource director the general counsel the Chief Executive Officerat or .
4. ANONYMOUS REPORTS.
- (a) Reporters seeking 100% anonymity should
use either the anonymous hotline orreport suspected violations by letter with no identifying details.
- (b) Although
will use its best efforts to maintain the anonymity of reporters, in certain cases an individual's identity may need to be disclosed to conduct a thorough investigation, to comply with the law, or to provide accused individuals their legal rights of defense.
5. CONTENTS OF REPORT.
In general, a report should contain as much information as possible, including the facts and dates that led you to suspect that a violation occurred. Although you are not required to give your name in your report, contact information will allow the compliance officer to follow up with you with further questions.
6. ANONYMITY AND CONFIDENTIALITY.
Regardless of the method you use to report suspected violations,
7. INVESTIGATING AND RESOLVING REPORTS.
- (a) Documentation. When a report is received, the compliance officer will create a file for the suspected violation, and will keep all documentation in that file.
- (b) Timeframe. Investigation of violations shall begin within
days of receipt of the report. Every effort shall be made to investigate and resolve reports promptly.
8. COMPLIANCE OFFICERS' DUTIES.
Compliance officers shall use their best efforts to investigate thoroughly and with consideration for the reporter all reports of suspected violations. Compliance officers must report annually on the submission and resolution of these matters to
10. GOOD FAITH.
11. NO RETALIATION.
12. OTHER LAW.
Nothing in this policy may be construed in a way that conflicts with any reporting obligations or protections afforded by state or federal law.
© LegalZoom.com, Inc. All rights reserved.