Whistleblower Policy

This Fraud Policy is established as guidance for the detection and prevention of fraud and is intended to promote consistent HILC behavior by assigning responsibility for the development of controls and conduct of investigations.

The policy applies to any fraud, or suspected fraud, involving employees, management, and board members, as well as other parties having a business relationship with HILC. Employees at all levels are responsible for setting the appropriate tone of intolerance for fraudulent acts by complying with all laws, regulations, and HILC policies.

Fraud is defined in this policy as a willful or deliberate act or failure to act to obtain an unauthorized benefit. The term fraud includes, but is not limited to, the following:

If there is a question as to whether an employee's or third-party individual's action constitutes fraud, the Executive Director should be contacted for guidance. If there is a question as to whether an employee's action constitutes fraud, third-party inquiries and guidance should be sought as to the best course of action, then the Audit Committee Chair should be contacted with information obtained to review and agree on the best course of action.

HILC requires its directors, managers, and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of HILC, each individual must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations.

It is the responsibility of all directors, managers, and employees to report fraudulent activities or suspected fraudulent activities in accordance with this Whistleblower Policy.

No director, manager, employee, or consultant who in good faith reports a fraudulent activity shall suffer harassment, retaliation, or an adverse employment consequence. An employee who retaliates against someone who has reported a fraudulent activity in good faith is subject to discipline up to and including termination of employment. This policy is intended to encourage and enable employees and others to raise serious concerns within HILC before seeking resolution outside HILC.

Anyone filing a complaint concerning a fraudulent activity or suspected fraudulent activity must be acting in good faith and have reasonable grounds for believing the information disclosed indicates evidence of fraud. Any allegations that prove not to be substantiated and were made maliciously or knowingly false will be viewed as a serious disciplinary offense.

An employee who discovers or suspects fraudulent activity should contact directly or submit an anonymous report to HILC's Executive Director immediately or, if uncomfortable with that reporting line, to the Executive Director and/or the Audit Committee Chair. The employee or other complainant may remain anonymous to the extent reasonable and consistent with conducting a proper investigation.

Any employee or other complainant reporting suspected or actual fraudulent activity should not contact the suspected individual(s) in an effort to determine facts and should not discuss the case, facts, suspicions, or allegations with anyone unless directed by HILC's legal counsel or the lead investigator.

The recipient of the complaint will notify the complainant, so long as that individual is known, and acknowledge receipt of the reported fraudulent activity or suspected fraudulent activity within five business days. All reports will be promptly investigated.

The Executive Director has primary responsibility for the investigation of all suspected fraudulent acts caused by employees or third parties, with oversight by the Executive Director and Audit Committee Chair. The Audit Committee Chair has primary responsibility for the investigation of all suspected fraudulent acts caused by HILC's management, including the Executive Director.

In conducting an investigation, the Executive Director and Audit Committee Chair may contact pertinent staff or individuals deemed knowledgeable of the suspected fraudulent activity for assistance and have authority to examine, copy, and/or remove all or any portion of files, desks, cabinets, and other storage facilities, including electronic storage, on the premises without prior knowledge or consent of an individual suspected of fraudulent actions.

Investigation results will be communicated to appropriate designated personnel, the Audit Committee Chair, the board's Audit Committee, and, if needed, the full board through the Audit Committee.

In instances where the investigation indicates possible criminal activity, decisions to refer the investigation results to the appropriate law enforcement and/or regulatory agency will be made in conjunction with legal counsel and senior management or the Audit Committee, depending on who is being investigated.

All participants in a fraud investigation shall keep the details and results of the investigation confidential. Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know.

Any person contacted by the media with respect to an investigation into fraudulent activity shall refer the media to the Executive Director or the Audit Committee Chair, whichever is more appropriate under the circumstances. The suspected fraud or investigation shall not be discussed with the media by any other person except in consultation with legal counsel.

Decisions related to remedial or disciplinary action are to be made by the individual's management. Any individual who engages in fraudulent activity may be subject to any combination of the following actions: