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SkyView Academy Whistleblower Policy General SkyView Academy’s Code of Ethics and Conduct ("Code") requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of SkyView Academy, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations . Reporting Responsibility It is the responsibility of all directors, officers, and employees to comply with the Code and to report violations or suspected violations in accordance with the Whistleblower Policy. No Retaliation No director, officer or employee who, in good faith, reports a violation of the Code shall suffer harassment, retaliation, or adverse employment consequences. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within SkyView Academy prior to seeking resolution outside SkyView Academy. Reporting Violations The Code addresses SkyView Academy's open-door policy and suggests that employees share their questions, concerns, suggestions, or complaints with someone who can address them properly. In most cases, an employee's supervisor is in the best position to address an area of concern. However, if you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor's response, you are encouraged to speak with someone on the Human Resources Team in the Business Department.. HR then is required to report suspected violations of the Code of Conduct to SkyView Academy's Compliance Officer, who has specific and exclusive responsibility to investigate all reported violations. For suspected fraud, or when you are not satisfied or uncomfortable following SkyView Academy's open door policy, individuals should directly contact SkyView Academy's Compliance Officer. Compliance Officer SkyView Academy's Compliance Officer is responsible for investigating and resolving all reported complaints and allegations concerning violations of the Code and, at his discretion, shall advise the Head of Schools/Head of Operations and/or the Finance Committee. TheCompliance Officer is required to report to the finance committee at least annually on compliance activity. The Organization's Compliance Officer is the chair of the Finance Committee. Accounting and Financing Matters The Finance Committee of the Board of Directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or financing. The Compliance Officer shall immediately notify the finance committee of any such complaint and work with the committee until the matter is resolved. Acting in Good Faith Anyone filing a complaint concerning a violation or suspected violation of the Code must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the Code. 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 or may be submitted anonymously. 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 Compliance Officer will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. |