The recipient of any reported Concern shall promptly communicate such Concern to the Company’s designated compliance personnel. The Company’s designated compliance personnel shall promptly provide written to the reporter that such Concern has been received. If the report has been submitted anonymously, the Company’s designated compliance personnel shall provide written confirmation to the extent possible.
The Company’s designated compliance personnel shall review within a reasonable time frame each Concern reported through any of the mechanisms for reporting Concerns listed above. The Concern will be assigned an identification number to enable tracking of the Concern and shall communicate the Concern to the appropriate Investigator for review and Investigation, if needed, with appropriate consideration regarding confidentiality concerns. Persons who have reported Concerns anonymously can use the identification number to provide additional information and receive a response relating to the Concern.
The Investigator will typically be from the Company’s designated compliance personnel, depending on the nature of the Concern and the persons involved. The Investigator shall prepare a plan of Investigation which the Company’s designated compliance personnel shall review and approve before the Investigation commences. A plan of Investigation should set forth the process and expected timing for conducting the Investigation, including persons to be interviewed, documents to be reviewed, reports to be prepared and the roles of Company personnel and outside advisors. Investigators may seek assistance in any Investigation from other Company personnel, including people outside the relevant business unit or corporate function. In addition, depending on the scope and nature of the Investigation, Investigators may require assistance from outside advisors (such as legal counsel, external auditors, accountants, fraud investigators, information technology experts, etc.) but shall obtain the prior approval of the Company’s designated compliance personnel before approaching or retaining such advisors.
The person who is the subject of the Investigation shall be notified in a timely manner about the Investigation and involved in the Investigation as deemed necessary and appropriate.
You are expected to cooperate when your assistance, or the assistance of any person under your supervision, is sought with respect to any Investigation.
The Company’s designated compliance personnel shall meet with the Investigator on a regular basis to provide oversight and receive updates on the progress of the Investigation.
In the event that the Concern involves any Director or Officer of the Company (whether in his or her role as a director, employee or officer of the Company or otherwise), the Audit Committee will make its report to the Board of Directors, exclusive of any Director or Officer involved in such Concern.
Investigations shall be treated as confidential to the extent possible and only discussed with those outside the investigation team on a need-to-know basis. You are required to keep confidential any information that you receive as part of an Investigation, including the existence of the Investigation, the persons involved and the factual, legal and ethical issues.