Whistleblower Protection Policy

Reporting Required

What to Report

All directors, officers, and employees of the Corporation must promptly report in compliance with this Policy any of the following situations of which the director, officer, and employee becomes aware or has reason to believe may exist:

1. violations of any applicable federal, state, or local law or regulation;
2. violations of any material policy of the Corporation, for example the Corporation’s Conflict of Interest Policy;
3. any questionable or improper matters regarding bookkeeping, accounting, internal accounting controls, or auditing matters; or
4. inappropriate handling or resolution of any complaint or matter previously reported under this Policy.

An activity is subject to reporting under this Policy regardless of whether or not such activity is within the scope of the employee’s official duties on behalf of the Corporation.

Retaliation Prohibited

No officer, director, or employee may take any action that is harmful to an individual, or discharge, demote, suspend, threaten, harass or in any manner discriminate against an individual in the terms and conditions of employment because of any lawful act done by the individual:

1. to report any matter that the individual reasonably believes must be reported under this Policy;
2. to participate in an investigation by a regulatory authority, law enforcement agency, member or committee of Congress, or any person with supervisory authority over the employee or who has the authority to investigate reports under this Policy;
3. to report truthful information relating to any state or federal offense to a law enforcement officer;
4. to provide information, cause information to be provided, or otherwise assist in an investigation regarding any conduct which the employee reasonably believes constitutes a violation of applicable law or fraud, when the investigation is brought by a governmental, regulatory, or law enforcement agency, a member or committee of Congress, a person with supervisory authority over the employee, or such other person working for the Corporation who has the authority to investigate, discover, or terminate improper conduct.

Any individual who has reason to believe that he or she has been subject to retaliation for making a report or participating in an investigation under this Policy must immediately report such alleged retaliation in accordance with Section II.A. and II.B. of this Policy. Any employee who retaliates against another employee for making a report or participating in an investigation under this Policy will be subject to disciplinary action, up to and including termination of employment.

Applicability to Volunteers, Independent Contractors, and Agents

Although not employees of the Corporation, the Corporation expects its volunteers, independent contractors, and agents with authority to act on behalf of the Corporation to observe high standards of business and personal ethics, especially in connection with their relationship to the Corporation. As such, the Corporation expects and encourages its volunteers, independent contractors, and agents with authority to act on behalf of the Corporation to report misconduct in compliance with this Policy using the procedures identified above.

Certificate of Adoption

The foregoing Whistleblower Protection Policy was adopted by the Board of Directors of the Corporation on the 23 day of March, 2021.