Prairie Meadows Whistleblower Policy
Adopted November 2005.
Our Code of Ethics and Business Conduct (the “Code”) requires our directors, officers
and employees to observe high standards of business and personal ethics in the
conduct of their duties and responsibilities. As employees and representatives of the
Organization, we must practice honesty and integrity in fulfilling our responsibilities and
comply with all applicable laws and regulations.
The Whistleblower Policy is intended to cover serious concerns that could have a large
impact on Prairie Meadows. The following are examples of actions or behavior that
should be reported:
- Fraud or deliberate error in the preparation, evaluation, review or audit of
any financial statement or accounting records of the Organization;
- Stealing or misappropriation of the Organization or its customers funds or
- Violations of laws, regulations, or Organization policy, including the Code
of Ethics and Business Conduct
- Deficiencies in or non-compliance with our Internal Controls; or
- Serious improper conduct.
It is the responsibility of all directors, officers and employees to comply with the Code
and to report violations or suspected violations in accordance with this Whistleblower
Violations or suspected violations may be submitted on a confidential basis by the
complainant or may be submitted anonymously. Reports of violations or suspected
violations will be kept confidential to the extent possible, consistent with the need to
conduct an adequate investigation.
Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation of the Code must
be acting in good faith and have reasonable grounds for believing the information
disclosed indicates a violation of the Code. Any allegations that prove not to be
substantiated and which prove to have been made maliciously or knowingly to be false
will be viewed as a serious disciplinary offense.
No director, officer or employee who in good faith reports a violation of the Code shall
suffer harassment, retaliation or adverse employment consequence. An employee who
retaliates against someone who has reported a violation in good faith is subject to
discipline up to and including termination of employment. This Whistleblower Policy is
intended to encourage and enable employees and others to raise serious concerns
within the Organization rather than seeking resolution outside the Organization.
The Code addresses Prairie Meadows’ open door policy and suggests that employees
share their questions, concerns, suggestions or complaints with someone who can
address them properly. In most cases, an employee’s supervisor is in the best position
to address an area of concern.
However, if you are not comfortable speaking with your supervisor or you are not
satisfied with your supervisor’s response, you are encouraged to speak with someone in
the Human Resources Department or anyone in management whom you are
comfortable in approaching. Directors or officers are required to report suspected
violations of the Code to the Internal Auditor or directly to the Audit Committee Chair.
For suspected fraud, or when you are not satisfied or uncomfortable with following the
Corporation’s Open Door Policy, any director, officer, employee, or other interested party
may report your complaint or concern anonymously by calling 1-877-778-5463. The
Ethics Line is monitored by an independent, third party company that facilitates and
documents your submissions and then quickly gathers and disseminates the information
via an Incident Report to the proper contacts provided by Prairie Meadows.
Accounting and Auditing Matters
The Audit Committee of the Board of Directors shall address all reported concerns or
complaints regarding corporate accounting practices, internal controls or auditing. The
Audit Committee Chair shall work with the Audit Committee until the matter is resolved.
Investigation and Resolution of Complaints
All reports will receive immediate attention and if appropriate, an investigation will
commence as soon as practical based on the risk assessment and exposure. As
appropriate, resources from the Human Resources, Security, and Internal Audit or any
other departments will be included to fully investigate the complaint. If necessary, legal
counsel and/or the Organization’s independent auditing firm will be involved in any
investigation. Subject to legal constraints, the complainant will receive information about
the resolution of any investigations.
Retention of Complaints and Reports of Resulting Action
Prairie Meadows will maintain a file of all complaints and concerns reported pursuant to
these procedures, tracking their receipt, investigation, evaluation and resolution, and of
the related reports issued in connection therewith, which summarize the results of the
related investigation and any corrective action taken. Copies of all such materials will be
retained in accordance with the Organization’s Retention Policy.
On at least a quarterly basis, the Audit Committee Chair will report to the Audit
Committee the receipt of any concerns or complaints, the current status of the
investigation, and the resolution at the end of the investigation.
The Whistleblower Policy will be communicated to all employees annually, will be posted
on the Organization’s website, incorporated into new employee orientation programs,
Code of Ethics training programs, and the Employee Handbook. The Human Resources
Department will be responsible for such communications.