About this copy. This is the published text. The names of individuals and any street addresses have been omitted. Nothing else has been changed.

Complete signed copies are on file with the Corporation and are available to anyone with a proper purpose under KRS Chapter 273.

Whistleblower Policy — Automate the Cloud Inc.

1. Purpose

To encourage directors, officers, volunteers, and any employees to report suspected wrongdoing, and to protect those who report from retaliation. This policy reflects the whistleblower-protection principles applicable to nonprofits and answers the corresponding IRS Form 990 governance question.

2. Scope

Covers good-faith reports of suspected: financial impropriety or fraud; theft or misuse of assets; violations of law or the Corporation's policies (including the Conflict of Interest Policy); and endangerment of health or safety.

3. Reporting Procedure

  • Ordinarily, report concerns to the President.
  • If the concern involves the President or Treasurer (or you are uncomfortable reporting to them), report instead to an independent director, who will bring it to the Board.
  • Reports may be made in writing or verbally and, where possible, should include enough detail to allow investigation.

4. No Retaliation

No one who makes a good-faith report may be subjected to retaliation, including harassment, removal from the board, termination, or any adverse treatment. Retaliation is itself a violation of this policy and grounds for removal.

5. Good Faith

Reports must be made in good faith with reasonable grounds. Knowingly false or malicious reports are a violation of this policy.

6. Handling of Reports

The person receiving a report (or the Board) shall promptly investigate, maintain confidentiality to the extent practical, and take appropriate corrective action. Matters involving a conflict of interest are handled under the Conflict of Interest Policy (the interested person is excluded from the investigation and decision).

7. Records & Review

The Board shall keep a confidential record of reports and their resolution. This policy is reviewed periodically and amended as needed.