Utilize this policy to establish procedures and standards for handling your company’s accounting and audit-related complaints. This policy outlines the audit committee's responsibilities in receiving, retaining, investigating and acting on complaints concerning questionable accounting practices, internal controls and auditing matters. It ensures that all allegations are dealt with seriously and systematically, providing clear channels through which employees and related parties can report concerns either openly, confidentially or anonymously.

The document also emphasizes protecting whistleblowers from retaliation, maintaining their confidentiality, and ensuring that their complaints are addressed promptly and thoroughly. It also details the involvement of external auditors or experts if needed and specifies the retention period for records related to such allegations. This policy is crucial for maintaining ethical standards and regulatory compliance in financial reporting and auditing, making it an essential tool for companies aiming to uphold integrity and transparency in their operations.

Procedures for receiving accounting allegations include the following:

• Any accounting allegation that is made directly to management (whether openly, confidentially or anonymously) should be promptly reported to the audit committee.
• Each accounting allegation made directly to the audit committee or forwarded to the audit committee by management (whether openly, confidentially or anonymously) should be reviewed by the audit committee.
• If the audit committee determines that management should investigate the accounting allegation, the audit committee will notify the general counsel in writing of that conclusion.
• Management should be free in its discretion to engage outside auditors, counsel or other experts to assist in the investigation and in the analysis of results.