All reports will be investigated promptly and thoroughly, and appropriate action will be taken. All reports will be treated as confidential to the extent practicable. All employees are expected to cooperate in investigations and refrain from interfering with or obstructing an investigation, misrepresenting or withholding information, attempting to discover the identity of anyone cooperating in an investigation, or breaching the confidentiality of an investigation. Doing so will result in appropriate disciplinary action up to and including termination.

Reports to the Reporting Hotline and submissions made via the Web may be made anonymously. The Reporting Hotline and Website are administered by an independent third party to ensure the reports remain anonymous. If an employee chooses to report a Concern anonymously, he/she should provide very specific, detailed incident information to allow for appropriate investigation.

For all internally reported Concerns, the reporter will be notified of the status of the Concern within 10 business days, whenever possible. For all hotline/website reported Concerns, the reporter will receive a report key to use to view the status of the Concern after 10 business days.

The director of internal audit will regularly report investigation results of reported Concerns to the Audit and Risk Committee of the Board of Trustees for their review.