Code Violations/Reporting

Section 4.0308-00 Code Violations/Reporting

The Human Resources Department is responsible for administering and updating this Code of Business Ethics. Depending on the nature of an alleged violation, the Chief Human Resources Officer or his/her designee would be responsible for conducting an investigation and would be responsible, together with appropriate management officials, for determining appropriate disciplinary action and reporting to the Board of Directors. NCBA CLUSA attempts to impose discipline for each Code of Conduct violation in a consistent manner appropriate to the nature of the violation, including termination of employment if circumstances warrant. NCBA CLUSA reserves the right, however, to determine, in its discretion, the appropriate level of discipline for any violation of the Code of Business Ethics.

All NCBA CLUSA employees are responsible for promptly reporting any issue or concern they believe in good faith may constitute a violation of this Code of Business Ethics or any other NCBA CLUSA policy. If you believe a violation of this code, or any other NCBA CLUSA policy, has occurred, please contact NCBA CLUSA’s Human Resources Department.

Any such complaints may be submitted in person, in writing or on an anonymous basis to a Human Resources representative.

INVESTIGATIONS BY GOVERNMENTAL AUTHORITIES

As a participant in highly regulated activities utilizing government grants, NCBA may at times be subject to inquiries and investigations by government agencies. NCBA is committed to cooperating with any such inquiry or investigation. All such interactions must be coordinated with the President/CEO to secure appropriate legal assistance to ensure that NCBA’s legal interests are protected.

Subsection 4.0308-01 Whistleblower Policy

Reporting Responsibility

It is the responsibility of all Board members, Officers, employees, and volunteers to report concerns about violations of NCBA CLUSA’s Code of Business Ethics or suspected violations of law or regulations that govern NCBA CLUSA’s operations.

Compliance Hotline for Financial Integrity

NCBA CLUSA has retained the services of Signius Communications to manage a hotline program to enable employees from any office site to report anonymously any incidents of theft, financial misconduct, or any wrongdoing. Signius Communications is an independent third party that is responsible for ensuring an unbiased communication of any reported information to NCBA CLUSA Board of Directors and management for evaluation and action.

Employees may report a concern by either of the following methods:

Protection for Whistleblowers and Witnesses Policy

It is the responsibility of all employees to comply with NCBA CLUSA’s policies, and to report violations or suspected violations in accordance with this Code of Business Ethics. An employee should be free to initiate good faith contact with any NCBA CLUSA personnel, or provide information in the context of an official investigation or other inquiry, without reprisal.

No employee shall be subject to reprisal as a result of having provided information in good faith regarding a suspected incident of fraud or corruption. A reprisal for the purposes of this policy is an act of retaliation on the part of a staff member’s colleagues, supervisors, or any NCBA CLUSA’s Senior Leadership carried out to punish a staff member for having provided such information. Reprisals are adverse actions on the part of co-workers or supervisors in response to the employee’s acting as whistleblower which could include harassment, discriminatory treatment, assignment of work outside of the corresponding position description, inappropriate evaluations of performance, inappropriate awards of merit pay, or the withholding of any other entitlement. For the purposes of this policy, a reprisal also includes the threat of reprisal.

No Senior Leader/Officer may use his or her position to influence an employee or prevent an employee from exercising their rights as provided in this policy. Any officer who is found to have engaged in such behavior shall be subject to disciplinary action.

The protection affirmed in this policy applies only to an employee acting in good faith and providing information which they reasonably believes is true. Providing information for motives of personal gain or with malicious intent, or information that is known to be false, is not protected by this Policy and may be subject to disciplinary action against the individual making the malicious allegation.

An employee who believes that they have been the subject of reprisal as described in this policy, should report their concerns to the Chief Human Resources Officer or to the Chair of NCBA CLUSA Board’s Audit Committee.

No Retaliation

It is contrary to the values of NCBA CLUSA for anyone to retaliate against any Board Member, Officer, Employee, or Volunteer who in good faith reports an ethics violation or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any law or regulation governing the operations of NCBA CLUSA. An employee who retaliates against another employee who has reported a violation in good faith is subject to discipline up to and including termination of employment.

An employee who believes that he or she has been the subject of reprisal as described in this policy should report their concerns to the Chief Human Resources Officer or to the Chair of the Board’s Audit Committee.

Reporting Procedure

The Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the organization prior to seeking resolution outside the organization. It is the responsibility of all Directors, Officers, and Employees to comply with the Code of Business Ethics and to report violations or suspected violations in accordance with this Whistleblower Policy. Employees should share their questions, concerns, suggestions, or complaints with an immediate supervisor. If an employee believes an immediate supervisor would stymie, prevent or inhibit remedial action, the employee should contact the Chief Human Resources Officer or contact the Whistleblower Hotline directly to ensure protection of anonymity.

The Whistleblower Hotline reports are not managed within NCBA CLUSA and are directly provided to Chairman of the Board of Directors, Vice Chairman of the Board of Directors, and the Chair of the Audit Committee.

Acting in Good Faith

Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations, that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false, will be viewed as a serious disciplinary offense.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

The NCBA CLUSA’s representative designated by the Board of Director’s will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

It is NCBA CLUSA’s policy to promote and implement prompt and consistent enforcement of this code, fair treatment for persons reporting unethical behavior, objective and clear standards for compliance and a fair process by which to determine violations of this code and other NCBA CLUSA policies. It is against NCBA CLUSA policy to retaliate against any employee for good faith reporting of violations of this code or any other NCBA CLUSA policy. Any employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to an including termination of employment. The Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the organization prior to seeking resolution outside of the organization.

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