ICC is committed to continuing its tax-exempt purposes and in remaining compliant with all applicable laws, rules, and regulations, including those concerning accounting and auditing, and prohibits fraudulent practices by any of its board members, officers, employees, or volunteers. This policy outlines a procedure for employees to report actions that an employee reasonably believes violate a law or regulation, or that constitutes fraudulent accounting or other practices. This policy applies to any matter which is related to ICC’s business and does not relate to private acts of an individual not connected to the business of ICC.

If an employee has a reasonable belief that ICC or any employee has engaged in any action that violates any applicable law, or regulation, including those concerning accounting and auditing, or constitutes a fraudulent practice, the employee is expected to immediately report such information to the Chief of Staff. If the employee does not feel comfortable reporting the information to the Chief of Staff, he or she is expected to report the information to the head of Human Resources.

All reports will be followed up promptly, and an investigation conducted. In conducting its investigations, ICC will strive to keep the identity of the complaining individual as confidential as possible while conducting an adequate review and investigation.

ICC will not retaliate against an employee in the terms and conditions of employment because that employee: (a) reports to a supervisor, to the Chief of Staff, the Board of Directors or to a federal, state or local agency what the employee believes in good faith to be a violation of the law; or (b) participates in good faith in any resulting investigation or proceeding, or (c) exercises his or her rights under any state or federal law(s) or regulation(s) to pursue a claim or take legal action to protect the employee’s rights. ICC may take disciplinary action (up to and including termination) against an employee who in management’s assessment has engaged in retaliatory conduct in violation of this policy.

In addition, ICC will not, with the intent to retaliate, take any action harmful to any employee who has provided to law enforcement personnel or a court truthful information relating to the commission or possible commission by ICC or any of its employees of a violation of any applicable law or regulation. Supervisors will be trained on this policy and ICC’S prohibition against retaliation in accordance with this policy.