Policy for Reporting Violations and Complaints
i. Policy Statement
One of our Company’s most valuable assets is its integrity. Protecting this asset is the job of everyone in the Company. We have established a Code of Business Conduct and Ethics to help our employees comply with the law and regulations applicable to our business and to maintain the highest standards of ethical conduct.
This policy is meant to supplement our Code of Business Conduct and Ethics by encouraging employees to report any suspected violations or concerns as to compliance with laws, regulations, our Code of Business Conduct and Ethics or other Company policies, or any complaints or concerns regarding the Company’s financial disclosure, accounting practices, internal accounting controls, or questionable accounting matters.
ii. Obligation to Report Suspected or Actual Violations; Anonymous Reporting
Reporting Generally
It is every employee’s obligation to report suspected or actual violations of laws, government rules and regulations, or the Company’s Code of Business Conduct and Ethics or other Company policies. You must report any suspected violations of the laws and rules that govern the reporting of the Company’s financial performance, and any complaint or concern regarding the Company’s financial disclosure, accounting practices, internal accounting controls, or questionable accounting matters.
You can report any such matters by the procedures set forth below. As noted below, supervisors and managers are required to report to the Compliance Officer any time they receive a report of a concern about our compliance with laws, the Code of Business Conduct and Ethics or other Company policy, any notice of any suspected wrong-doing by any Company employee, officer or director, any complaint or concern about the Company’s financial disclosure, accounting practices, internal accounting controls, or questionable accounting matters.
Anonymous Reporting
Alternatively, if you wish to report any such matters anonymously, you may do so as follows:
Mail a description of the suspected violation or other complaint or concern to:
SISTAR, Attention: Compliance Officer
iii. Treatment and Retention of Complaints and Reports
Each supervisor and manager shall report any suspected violation, concern or complaint reported to such person by employees or other sources to the Compliance Officer to assure proper treatment and retention of complaints, concerns or notices of potential violations.
In addition, employees should take note that persons outside the Company may report complaints or concerns about suspected violations, or concerns regarding accounting matters or internal accounting controls. These concerns and complaints should be reported immediately on receipt to the Compliance Officer.
The Compliance Officer shall promptly consider the information, reports or notices received under this policy or otherwise and take the appropriate action, including investigation as appropriate, in accordance with the law, governmental rules and regulations, the Company’s Code of Business Conduct and Ethics and otherwise consistent with good business practice.
The Audit Committee shall be notified promptly of all complaints determined to pertain to accounting matters or internal accounting controls and shall determine the planned course of action with respect to the complaint, including determining that an adequate basis exists for commencing an investigation. The Compliance Officer will then appoint one or more internal and/or external investigators to promptly and fully investigate each viable claim under the direction and oversight of the Audit Committee or such other persons as the Audit Committee determines to be appropriate under the circumstances.
The Compliance Officer will confidentially inform the reporting person (if his or her identity is known) that the complaint has been received and provide him or her with the name of, and contact information for, the investigator assigned to the claim. Upon a report to the Compliance Officer, all notices or reports of suspected violations, complaints or concerns received pursuant to this policy shall be recorded in a log, indicating the description of the matter reported, the date of the report and the disposition thereof, and the log shall be retained for five years. This log shall be maintained by the Compliance Officer.
iv. Statement of Non-Retaliation
It is a federal crime for anyone to retaliate intentionally against any person who provides truthful information to a law enforcement official concerning a possible violation of any federal law. Moreover, the Company will not permit any form of intimidation, harassment, threat, demotion, discharge, discrimination or retaliation by any officer, employee, contractor, subcontractor or agent of the Company against any employee because of any lawful act done by that employee to:
- provide information or assist in an investigation regarding any conduct which the employee reasonably believes constitutes a violation of laws, rules, regulations, the Company’s Code of Business Conduct and Ethics, or any Company policies; or
- file, testify, participate in, or otherwise assist in a proceeding relating to a violation of any law, rule or regulation.
v. Any such action is a violation of Company policy and should be reported immediately under this policy.
If it is determined that an employee has experienced any improper employment action in violation of this policy, we endeavor to promptly take appropriate corrective action.
vi. Statement of Confidentiality
The Company will, to the extent reasonably possible, keep confidential both the information and concerns reported under this policy, and its discussions and actions in response to these reports and concerns. In the course of its investigation, however, the Company may find it necessary to share information with others on a “need to know” basis.