Procedure for Reporting Violations

Trustees, officers, or staff members should share their complaints, concerns and information about suspected violations with someone who can address them properly. In most cases, a staff member's supervisor is in the best position to address an area of concern. However, if the staff member is not comfortable speaking with her/his supervisor, or is not satisfied with the supervisor's response, the staff member is encouraged to speak with the Human Resources Director or anyone in management whom the staff member is comfortable in approaching. Managers are required to report suspected accounting, legal or regulatory violations or violations of the Code of Ethics to the Corporation's Compliance Officer, who has specific and exclusive responsibility to investigate all reported violations. In the case of suspected fraud, an individual should contact the Corporation's Compliance Officer directly.

Compliance Officer

The Corporation's Compliance Officer is responsible for investigating and reporting and following-up on all reported complaints, concerns and suspected violations and shall advise the President and if required as described below under "Legal and Accounting Matters," shall advise the Audit Committee of the Board of Trustees. The Compliance Officer is required to report to the Audit Committee annually on all reported violations which are brought to her/his attention.. The Corporation's Compliance Officer is the Vice President, Chief Administrative Officer and Corporate Secretary. If a trustee, officer, or staff member thinks that it is inappropriate to report a complaint, concern or suspected violation to the Compliance Officer, the complainant should report such matters to the Vice President and Director, Strategic Planning and Program Coordination.

No Retaliation

No trustee, officer, or staff member who in good faith reports a complaint, concern or suspected violation in accordance with this Whistleblower Policy shall suffer harassment or retaliation. A trustee, officer, or staff member who retaliates against someone who has reported a violation is subject to discipline up to and including removal from the Board of Trustees or termination of employment.

Legal and Accounting Matters

The Compliance Officer shall immediately report to the Audit Committee, and the Audit Committee shall address, all reported complaints, concerns or suspected violations regarding the Corporation's accounting, internal accounting controls or auditing matters or the Corporation's legal or regulatory requirements.

Confidentiality

Complaints, concerns and suspected violations may be submitted to the Compliance Officer on a confidential basis by the complainant or may be submitted anonymously. Reports of complaints, concerns or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct a thorough investigation.

Handling of Reported Violations

The Compliance Officer shall notify the sender and acknowledge receipt of the complaint, concern or suspected violation within seven days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by an investigation.

Records

The Compliance Officer shall retain for a period of at least seven years all records relating to any complaint, concern or suspected violation reported to her/him in accordance with this Whistleblower Policy.