1-14 Whistleblower Policy

A whistleblower as defined by this policy is a team member who reports an activity that they consider to be illegal or dishonest. Illegal or dishonest activities may include but are not limited to violations of federal, state, or local laws such as charging for services not performed or for goods not delivered; and/or other fraudulent financial reporting. If a team member, exercising sound judgment, has knowledge of or a concern of illegal or dishonest fraudulent activity, the team member is to contact their immediate manager or HR. A team member who intentionally files a false report of wrongdoing may be subject to corrective action, up to and including termination. Appropriate management officials, not the whistleblower, are responsible for investigating the activity and determining fault or corrective measures.

Whistleblower protections are provided for confidentiality and against retaliation. Where possible, the confidentiality of the whistleblower will be maintained, however, identity may need to be disclosed to conduct a thorough investigation, to comply with the law and/or to provide accused individuals their legal rights of defense. CODE Staffing will not retaliate or allow retaliation against a whistleblower, in the form of an adverse employment action or treatment. Any whistleblower who believes they are being retaliated against should immediately contact the manager or HR. The right of a whistleblower for protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated.

All reports of illegal and dishonest activities will be promptly submitted to HR, who is responsible for investigating and coordinating corrective action. Team members with any questions regarding this policy should contact HR.