Whistleblower Protection Policy

I. Purpose

The Corporation is committed to honest, ethical and lawful conduct, full, fair, accurate, timely and transparent disclosure in all public communications, and compliance with applicable laws, rules and regulations. In furtherance of these commitments, all directors, officers, employees, staff, contractors, volunteers and members of the Corporation (each, a “Covered Person”) must act in accordance with all applicable laws and regulations, and with the policies of the Corporation at all times, and assist in ensuring that the Corporation conducts its business and affairs accordingly.

This Whistleblower Policy (a) establishes procedures for the reporting and handling of concerns regarding action or suspected action taken by or within the Corporation that is or may be illegal, fraudulent or in violation of any policy of the Corporation, as well as any other matter that could cause serious damage to the Corporation’s reputation (each, a “Concern”), and (b) prohibits retaliation against any Covered Person who reports a Concern in good faith.

By appropriately responding to Concerns, we can better support an environment where compliance is valued and ensure that the Corporation is meeting its ethical and legal obligations.

II. When to Raise a Concern

A Covered Person has an affirmative duty to disclose to and seek guidance from an appropriate supervisor or manager if he/she believes any Covered Person or other person associated or doing business with the Corporation has engaged, is engaging, or may engage in any illegal or unethical behavior or has violated, or may violate any law, rule, regulation or policy of the Corporation. Such reportable activity may include, for example, financial wrongdoing (including circumvention of internal controls or violation of the accounting policies of the Corporation), fraud, harassment, or any other illegal, unethical, or proscribed conduct. While Concerns may be submitted at any time, Covered Persons should endeavor to report a Concern as soon as reasonably possible after becoming aware of the matter.

III. How to Raise a Concern

Concerns may be submitted either in writing or orally. No form is required to submit a
concern, but you are encouraged to provide as much information and detail as possible so that the Concern can be properly investigated. A Concern may be submitted:

A) By discussing it with a supervisor or manager, who will in turn forward the Concern to Executive Director for review where appropriate; or

B) If the supervisor or manager is a subject of Concern, it may be forwarded to the Executive Director.

C) If the Executive Director is a subject of the Concern, it will be forwarded to the Board President for review where appropriate; or

D) If both the Executive Director and Board President are subjects of the Concern, it will be forwarded to the Chair of the Personnel Committee.

E) If all above parties are subject of the Concern it will be forwarded to a non-involved Board Member in good standing.

IV. Confidentiality

All Concerns received will be treated confidentially or anonymously, as applicable, to the extent reasonable and practicable under the circumstances.

V. No Retaliation Against Whistleblowers

It is the Corporation’s policy to encourage the communication of bona fide Concerns relating to the lawful and ethical conduct of the Corporation’s business. It is also the policy of the Corporation to protect those who communicate bona fide Concerns from any retaliation for such reporting. No adverse employment action may be taken and retaliation is strictly prohibited, including, without limitation, intimidation, harassment, discrimination, coercion, or otherwise, whether express or implied, against any director, officer, employee, staff, contractor, volunteer or member of the Corporation who in good faith reports any Concern or assists in an investigation of, or the fashioning or implementation of any corrective action or response made in connection with, any Concern. Any person who violates this prohibition against retaliation will be subject to
appropriate disciplinary action, which may include termination of employment or other relationship with the Corporation.

VI. Policy Distribution

A copy of this Policy shall be distributed to each Covered Person promptly following the
adoption of or amendments to this Policy, and at such time as a person becomes a Covered Person.

Approved: by the Board 8/4/15