• No director, officer, employee, volunteer, or contractor who in good faith reports a violation of the employee agreements, or policies, or law shall suffer harassment, retaliation, or adverse employment consequence. 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 SunWater Spa prior to seeking resolution outside the organization.

• Any good faith report, concern, or complaint is fully protected by this policy, even if the report, question, or concern is, after investigation, not substantiated. 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 of the policy or law. Any allegations that prove not to be substantiated and have been made maliciously or with the knowledge that they were false will be treated as a serious disciplinary offense.

• Upon the request of the complainant, we will use our best efforts to protect the confidentiality of the complainant for any good faith report. 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.

• All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. The complainant will be informed that follow-up has or is occurring within two weeks after the complaint or report has been received. The COO and the CFO shall be informed of all such complaints or reports.

updated 11/28/21