Whistleblower Policy

Introduction and Summary

The Siemon Company (Siemon) encourages its employees, suppliers, channel partners customers and other stakeholders to report violation of any law, regulation, Siemon Code of Conduct or other policies (a Breach). Those who report a Breach in good faith shall be protected. Siemon does not tolerate any form of threat, retaliation or other action against those who have reported Breaches in good faith.

This policy also establishes procedures for providing access to the whistleblower reporting system, enabling submittal, and for vetting, investigating and resolving logged whistleblower complaints.

Scope

The whistleblower policy and system is intended solely for the purpose of identifying and addressing incidents that are unlawful, unethical or that violate our company or supplier codes of conduct. All other types of incidents or concerns should be addressed directly with the individual(s) involved, a Company Manager or a Human Resources Representative.

This policy applies to all employees, suppliers, channel partners, customers and other stakeholders of the organization. It covers all suspected illegal or unethical activities, including but not limited to:

• Accounting or auditing matters
• Fraud or theft
• Discrimination or harassment
• Environmental violations
• Persistent safety hazards/violations not adequately addressed through other systems
• Compliance with laws and regulations
• Any other violation of Siemon’s Company Code of Conduct or Supplier Code of Conduct

Access

Employees, suppliers, channel partners, customers and other stakeholders who witness or suspect illegal or unethical activities may report them to any of the following:

• Their immediate supervisor
• The Human Resources Department
• The CEO or other Officer (VP or C-level positions) or Board member
• A designated whistleblower hotline which can be reached at: Whistleblower_Hotline@siemon.com*

* The whistleblower hotline is administered by the VP of Human Resources and overseen by the Company’s Board of Directors.

Open access is provided to this system at siemondev.wpenginepowered.com/whistleblower. This site provides an overview of Siemon’s whistleblower policy and the email address provided above.

Reports may be made in writing or orally and should be factual and contain as much specific information as possible. Hearsay and suspicions that are not supported by fact are strongly discouraged. If an employee, supplier, channel partner, customer or other stakeholder is concerned about retaliation, they may report the activity anonymously or through an intermediary with assurance of complete confidentiality.

Reporting

The basic principle of the Whistleblower Policy is that it provides the Company an opportunity to address Breaches promptly, fairly and effectively before requiring outside intervention or public disclosure. Before, during and after the internal handling of the Breach, all parties shall avoid any form of external or internal publicity. Any unlawful conduct should immediately be reported to local law enforcement.

Investigation and Closure

All reports of suspected illegal or unethical activities will be investigated promptly and thoroughly. The investigation will be conducted by a neutral party, such as the VP of Human Resources or an outside investigator, when warranted. All submittals to the Whistleblower hotline and any other whistleblower event that is brought to the attention of the Human Resources Department shall be logged by the VP of Human Resources. The log shall also include the current status of each event (e.g., dropped (no action taken), open or closed). All closed whistleblower submittals shall be documented in terms of investigations, findings and any actions taken.

While we are committed to reviewing and prioritizing all hotline submittals, Siemon has no obligation to respond directly to the submitter. We reserve the right to contact the submitter, as deemed necessary to complete our investigation. All submittals to the hotline email address will receive this automated response:

“Thank you for contacting Siemon’s Whistleblower Hotline. All submittals are handled confidentially with the assurance that fact-based accounts indicating violations of Siemon or Supplier Codes of Conduct will have no negative repercussions on the submitter. While we are committed to reviewing and prioritizing all hotline submittals, Siemon has no obligation to respond directly to the submitter. We reserve the right to contact the submitter, as deemed necessary to complete our investigation.”

Remediation

If an investigation finds that illegal or unethical activity has occurred, the organization will take appropriate corrective action. This may include disciplinary action against the individuals involved, restitution to victims, termination of employment and customer, channel partner or supplier agreements or changes to policies or procedures.

Retaliation

The organization will not retaliate against any individual who reports suspected illegal or unethical activities in good faith. Retaliation may include any adverse employment action, such as termination, demotion, or loss of benefits.

Confidentiality

All complaints will be dealt with in a confidential manner. Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate investigation of the complaint.

Enforcement

This policy will be enforced by the VP of Human Resources with oversight from the Board of Directors. Employees, suppliers, channel partners, customers or other stakeholders who believe that they have been retaliated against for reporting suspected illegal or unethical activities may file a complaint with the VP of Human Resources who will investigate the complaint and take appropriate action.

Oversight

Periodic reviews of the Whistleblower log and documentation of investigations, findings and actions, including random audits, shall be conducted by designated members of Siemon’s Board of Directors, which shall include at least one outside Director. Any designated Director, including the outside Director shall have:

1. Open access to all whistleblower reports at any time upon request.
2. Discretion to send any whistleblower report out for an independent review or independent investigation.

Notwithstanding the foregoing, any designated inside Director shall not have access to logs in which the inside Director or any direct reports of the inside Director is named. Such claims shall be reviewed by the outside Director who in his/her sole discretion may elect to send a whistleblower report out for an independent review and investigation.

Questions

If you have any questions about this policy, please contact the VP of Human Resources.