APPENDIX B: COMPLAINT REVIEW POLICY * * * [NAME OF CORPORATION] COMPLAINT REVIEW POLICY ARTICLE I INTRODUCTION In accordance with Corporation’s Whistleblower Policy (the this Complaint Review Policy sets forth “Policy”), procedures to be followed by the Corporation upon receipt of a complaint covered under the Policy. ARTICLE II COMPLIANCE OFFICER the Compliance Officer is responsible for promptly investigating all [Except as provided in Article VI,] complaints. If warranted by the investigation, the Compliance Officer will, in consultation with the Board of Directors and, if necessary, legal counsel, cause appropriate corrective action to be taken. In the event that a complaint concerns the Compliance Officer, the complaint shall be investigated by [designated officer] under close supervision of the Board of Directors. ARTICLE III COMPLAINT REVIEW PROCEDURE The Compliance Officer will notify the complainant and acknowledge receipt of a complaint within [five to ten] business days, but only to the extent that the complainant’s identity is disclosed or a return address is provided. The Compliance Officer will make initial inquiries in consultation with legal counsel, if necessary, to determine whether further investigation is necessary or appropriate. The Compliance Officer will manage any subsequent investigation, and may request the assistance of legal counsel or other parties as he or she deems necessary or appropriate. The Compliance Officer, or his or her designee, will fully investigate the complaint, meeting separately with the complainant and with others who either are named in the complaint or who may have knowledge of the facts set forth in the complaint. The Compliance Officer will explore anonymous complaints to the extent possible, but will weigh the prudence of continuing such investigations against the likelihood of confirming the alleged facts or circumstances from attributable sources. Upon completion of the investigation, the complainant will be notified about what actions will be taken, to the extent reasonably possible and consistent with any privacy or confidentiality limitations. If no further action or investigation is to follow, an explanation for the decision will be given to the complainant. ARTICLE IV CONFIDENTIALITY
APPENDIX B: COMPLAINT REVIEW POLICY * * * [NAME OF CORPORATION] COMPLAINT REVIEW POLICY ARTICLE I INTRODUCTION In accordance with Corporation’s Whistleblower Policy (the “Policy”), this Complaint Review Policy sets forth procedures to be followed by the Corporation upon receipt of a complaint covered under the Policy. ARTICLE II COMPLIANCE OFFICER [Except as provided in Article VI,] the Compliance Officer is responsible for promptly investigating all complaints. If warranted by the investigation, the Compliance Officer will, in consultation with the Board of Directors and, if necessary, legal counsel, cause appropriate corrective action to be taken. In the event that a complaint concerns the Compliance Officer, the complaint shall be investigated by [designated officer] under close supervision of the Board of Directors. ARTICLE III COMPLAINT REVIEW PROCEDURE The Compliance Officer will notify the complainant and acknowledge receipt of a complaint within [five to ten] business days, but only to the extent that the complainant’s identity is disclosed or a return address is provided. The Compliance Officer will make initial inquiries in consultation with legal counsel, if necessary, to determine whether further investigation is necessary or appropriate. The Compliance Officer will manage any subsequent investigation, and may request the assistance of legal counsel or other parties as he or she deems necessary or appropriate. The Compliance Officer, or his or her designee, will fully investigate the complaint, meeting separately with the complainant and with others who either are named in the complaint or who may have knowledge of the facts set forth in the complaint. The Compliance Officer will explore anonymous complaints to the extent possible, but will weigh the prudence of continuing such investigations against the likelihood of confirming the alleged facts or circumstances from attributable sources. Upon completion of the investigation, the complainant will be notified about what actions will be taken, to the extent reasonably possible and consistent with any privacy or confidentiality limitations. If no further action or investigation is to follow, an explanation for the decision will be given to the complainant. ARTICLE IV CONFIDENTIALITY
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