Whistleblower Policy

Summary

This whistleblower policy and procedures template may be used to comply with the requirements of Section 806 of the Sarbanes-Oxley Act of 2002. This template includes practical guidance and drafting notes. Section 806 of the Sarbanes-Oxley Act of 2002 prohibits retaliation against an employee for lawfully providing information or assistance in an investigation by the Securities and Exchange Commission (SEC) or other federal regulatory or law enforcement agency, any member or committee of Congress, or any person with supervisory authority over the employee into any conduct that the employee reasonably believes constitutes a violation. This policy provides procedures for the reporting of violations to the chief compliance officer and the audit committee of the company. For more information, see Whistleblower Protections under Dodd-Frank and Sarbanes-Oxley. For a full listing of key content covering employee handbook considerations, see Employee Handbook Resource Kit. For videos on whistleblowing from an employee’s perspective, see How to Speak Out & Listen Up: Part 1 Video and How to Speak Out & Listen Up: Part 2 Video.