• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • EMPLOYEE COMPLAINTS ON ACCOUNTING AND AUDITING MATTERS
SCOPE
This policy is the responsibility of the Audit Committee of the Board of Directors of Algoma. PRACTICE Submitting Reports
A report may be submitted by any of the means described above in the name of the employee submitting the report ,in the name of the employee submitting the report with a request for confidential treatment, or anonymously. A request for confidential treatment means that the name of the employee submitting the report will be revealed only to the person to whom the report has been submitted, to the members of the Audit Committee, and to such other persons as the Audit Committee reasonably determine is advisable in order to carry out an appropriate and adequate evaluation or investigation of the matters described in the report. Reports submitted anonymously means that the identity of the employee submitting the report will not be known to anyone except to the independent web service provider. HANDLING OF REPORTS Receipt of Report Reports of the type contemplated by this Policy are received by both the Chair of the Audit Committee and the Vice President Human Resources. The Chair of the Audit Committee is responsible for overseeing and directing the evaluation of the reports. Any evaluation can be made independently of Algoma management if the Chair of the Audit Committee so chooses under the circumstances. Any decision by the Chair of the Audit Committee to review or investigate any matter brought to its attention will not in any way be a determination that any actions or inactions that are the subject of the report have, in fact, occurred or constitute questionable accounting or auditing matters. Conduct of Investigations If the Chair of the Audit Committee determines that further review or investigation of the matters raised in a report would be appropriate under the circumstances, the Chair of the Audit Committee will promptly notify the appropriate parties. The Chair of the Audit Committee may notify Algoma's management or its outside auditors of the receipt of a report and/or the progress or results of any review and/or investigation of the report and will provide such level of detail as may be necessary. At the conclusion of a review or investigation, the Chair of the Audit Committee will determine what, if any, remedial action is appropriate. The Chair of the Audit Committee will consult with and coordinate with both the full Audit Committee and the Board of Directors as the Chair of the Audit Committee determines appropriate. Response to Employee Upon receipt of a report, unless the report has been submitted anonymously, the Vice President Human Resources will acknowledge receipt of the report in writing. If a report has been submitted anonymously, it is the responsibility of the employee submitting the report to follow-up on the status of how their issue is being investigated and/or resolved. To do this, employees will receive, at the time they file a report, a unique 15 digit confirmation number to use at a later date to access the system. NON- RETALIATION Algoma prohibits its employees, officers and directors from taking any retaliatory action against any employee who has submitted a complaint as contemplated by this Policy. For Algoma to implement this policy effectively, it is critical that all employees and other persons respond to and report any concerns of retaliatory behavior. Algoma will review promptly any complaint of retaliatory or other similar behavior. Complaints and investigations will be handled in a confidential manner. EFFECTIVE DATE This Policy shall become effective on January 1, 2005. |
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