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I 1 SAMPLE WHISTLEBLOWER POLICY Provided by: Jeffrey S. Tenenbaum, Esq. Venable LLP Washington, D.C. 202/344-8138 Telephone jstenenbaum@venable.corn Email Purpose The ABC Association is committed to high standards of ethical, moral and legal business conduct. In line with this commitment, and ABC's commitment to open communication, this policy aims to provide an avenue for employees to raise concerns and reassurance that they will be protected from reprisals or victimization for whistleblowing. This whistleblowing policy is intended to cover protections for you if you raise concerns regarding ABC, such as concerns regarding: U incorrect financial reporting; U unlawful activity; U activities that are not in line with ABC policy, including the Code of Business Conduct; or U activities, which otherwise amount to serious improper conduct. Safeguards Harassment or Victimization - Harassment or victimization for reporting concerns under this policy will not be tolerated. Confidentiality - Every effort will be made to treat the complainant's identity with appropriate regard for confidentiality. Anonymous Allegations - This policy encourages employees to put their names to allegations because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified. Concerns expressed anonymously will be explored appropriately, but consideration will be given to: U The seriousness of the issue raised; U The credibility of the concern; and U The likelihood of confirming the allegation from attributable sources. Bad Faith Allegations- Allegations in bad faith may result in disciplinary action. Procedure: 1.Process for Raising a Concerti Reporting- The whistleblowing procedure is intended to be used for serious and sensitive issues. Such concerns, including those relating to financial reporting, unethical or illegal conduct, may be reported directly to: [your general counsel's name,title,telephone number,address,email address]