215 – WHISTLEBLOWING & RETALIATION

The Code of Ethics of the Company states that it conducts its business fairly, impartially, in an ethical and proper manner, and in compliance with all laws and regulations. (See Code of Ethics policy). In conjunction with this Code, it is a violation to retaliate in any manner against an employee for making a report or allegations regarding ethical or legal non-compliance. 

 It is the responsibility of all employees, Board Members, and volunteers to comply with the Company Code of Ethics and in good faith report any violations or suspected violations in accordance with this Whistleblower Policy. 

 Employees have the right to report, without suffering retaliation, any activity by the Company or an employee that the employee reasonably believes: 1) violates any state or federal law; 2) violates or amounts to noncompliance with a state or federal rule or regulation; 3) violates the Code of Ethics; 4) involves an actual or perceived conflict of interest; or 5) violates fiduciary responsibilities by a corporation or limited liability Company to its shareholders, investors, or employees. 

 Also covered by this policy is an employee’s refusal to participate in an activity that would result in a violation of state or federal statutes, or a violation or noncompliance with a state or federal rule or regulation. The Company will treat all communications under this policy in a confidential manner to the extent possible in the execution of a complete and fair investigation, utilizing as deemed necessary, its Board of Directors or outside independent professionals. The Company will not permit any negative or adverse actions to be taken against any individual for making a good faith report internally or to a public entity of a possible violation of its Code of Ethics or applicable law or against any employee or representative who in good faith assists in the investigation of a reported violation. 

 Examples of retaliatory behavior include (but are not limited to):

  •  Firing or laying off

  • Blacklisting

  • Demoting

  • Denying overtime or promotion

  • Disciplining

  • Denial of benefits

  • Failure to hire or rehire

  • Intimidation

  • Making threats

  • Reassignment affecting prospects for promotion

  • Reducing pay or hours

 In some instances, the above actions may have a legitimate business justification. It is important to report potential retaliatory actions to the Human Resources department. An employee who retaliates against someone who has, in good faith, reported a violation or allegation, is subject to discipline up to and including termination of employment. 

 Employees and others may communicate suspected violations of the Company Code of Ethics, applicable law, safety concern, or other wrongdoing by contacting their immediate Supervisor and using the Issue Reporting process (see Issue Reporting policy). Employees may also report information regarding possible unlawful activity to an appropriate government or law enforcement agency but are encouraged to use the internal reporting process to allow the Company to fully investigate and respond to the concern.

 Employees should contact the Human Resources department, the CEO, or if appropriate, the Chair of its Board of Directors with any questions regarding this policy. 

@2021 The DPI Group. All Rights Reserved. Revision Dates: 02/10/2021 - The DPI policies do not form a contract, express or implied, nor do they guarantee employment for any specific length of time. Employment with The DPI Group or any subsidiary is at-will. This means that either the employee or employer can terminate the employment relationship at any time, for any reason. No statements made by any supervisor or manager can alter this at-will relationship. The at-will relationship can only be changed through a signed written agreement that specifically sets forth the terms between the employee and the President/Chief Executive Officer of the Company.