Whistleblower Policy

Under this policy, a whistleblower is an employee who reports an activity that he/she considers to be illegal or dishonest to a party specified herein. Examples of illegal or dishonest activities are violations of federal, state, or local laws or billing for goods or services not provided.

If an employee has knowledge of or a concern of illegal or dishonest fraudulent activity, the employee must contact Human Resources or an officer of the Company. Human Resources is responsible for conducting investigations, except if the allegations involve Human Resources, in which case the officers of the Company will appoint another person to investigate. Employees must exercise sound judgment to avoid baseless allegations, and employees are not responsible for investigating the alleged wrongful conduct. An employee who intentionally files a false report of wrongdoing will be subject to discipline up to and including termination.

The confidentiality of the whistleblower will be maintained as much as possible, however, compete confidentiality cannot be guaranteed since a thorough investigation will be conducted. The Company will not retaliate against a whistleblower. Any whistleblower who believes he/she is being retaliated against must contact Human Resources or an officer of the Company immediately.

External stakeholders may report an incident to report@dillongage.com.