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 impact 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 assets
  • Violations of laws, regulations, or Organization policy, including the Code
  • Deficiencies in or non-compliance with our Internal Controls
  • Serious improper conduct

Reporting Responsibility

All directors, officers, and employees are responsible for complying with the Code and reporting violations or suspected violations.


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 act 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 have been made maliciously or knowingly false will be viewed as a serious disciplinary offense.

No Retaliation

No director, officer, or employee who reports a violation of the Code in good faith shall suffer harassment, retaliation, or adverse employment consequences. 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.

Reporting Violations

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 adequately. In most cases, an employee’s supervisor is best positioned to address an area of concern.

However, suppose you are uncomfortable speaking with or dissatisfied with your supervisor’s response. In that case, you are encouraged to talk with someone in the Human Resources Department, Internal Audit, or anyone in management you are comfortable approaching. Directors or officers must report suspected violations of the Code to the Internal Auditor or directly to the Audit Finance 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 the free hotline number 877-778-5463 or report it online at (Username: Prairie; Password: Meadows). 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 Finance Audit Committee of the Board of Directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls, or auditing. The Finance Audit Committee Chair shall work with the Finance 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. Resources from the Human Resources, Security, and Internal Audit or any other departments will be included to investigate the complaint thoroughly. Legal counsel and/or the Organization’s independent auditing firm will be involved in any investigation if necessary. Subject to legal constraints, the complainant will receive information about resolving any investigations.

Retention of Complaints and Reports of Resulting Action

Prairie Meadows will maintain a file of all complaints and concerns reported according to these procedures, tracking their receipt, investigation, evaluation, and resolution, the related reports issued in connection, and summarizing the results of the related investigation and any corrective action taken. The Organization’s Retention Policy will retain copies of all such materials.


The Finance 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.

Employee Communication

The Whistleblower Policy will be communicated to all employees annually, posted on the Organization’s website, and 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.