Whistleblower Protection Policy Draft

I — Purpose

Access100 (the “Corporation”) is committed to operating in accordance with all applicable laws and regulations and maintaining the highest standards of ethical conduct. This Whistleblower Protection Policy is intended to encourage and enable Directors, officers, employees, and volunteers to raise serious concerns about suspected illegal, unethical, or improper conduct within the Corporation without fear of retaliation.

II — Scope

This policy applies to all Directors, officers, employees, and volunteers of the Corporation. It covers concerns about:

• Violations of federal, state, or local laws or regulations;
• Fraudulent financial reporting or accounting practices;
• Misappropriation of Corporation assets;
• Violations of the Corporation’s Conflict of Interest Policy;
• Violations of the Corporation’s Code of Ethics;
• Retaliation against anyone who reports a concern under this policy;
• Any other conduct that constitutes a substantial and specific danger to public health or safety; and
• Any other serious violation of Corporation policies.

III — Reporting Procedures

A — How to Report

If you have a concern about suspected wrongdoing, you are encouraged to report it using one of the following methods:

1. Direct Report to Supervisor: If you are comfortable doing so, first discuss your concern with your immediate supervisor or the person to whom you report.
2. Report to Chair: If you are not comfortable reporting to your supervisor, or if you believe your supervisor is involved in the suspected wrongdoing, report directly to the Chair of the Board of Directors.
3. Report to Designated Officer: You may also report concerns to the Corporation’s designated Compliance Officer or the Chair of the Audit/Finance Committee.
4. Written Report: Submit a written report to:
   • Access100 Board of Directors
   • 1050 Queen St #100, Honolulu, HI 96814
   • Mark envelope: CONFIDENTIAL — WHISTLEBLOWER REPORT

B — Information to Include

When reporting a concern, please provide as much detail as possible, including:

• A description of the suspected wrongdoing;
• The names of individuals involved;
• Dates, times, and locations of relevant events;
• Any documents or evidence supporting your concern;
• Names of potential witnesses; and
• Your contact information (unless you wish to remain anonymous).

C — Anonymous Reports

While we encourage you to identify yourself to facilitate investigation, you may submit anonymous reports. However, please be aware that anonymous reports may be more difficult to investigate and substantiate.

IV — Investigation Process

A. All reports will be promptly and thoroughly investigated by an appropriate person or committee designated by the Board of Directors.

B. The investigation will be conducted confidentially to the extent possible while still allowing for an effective investigation.

C. The person or committee conducting the investigation may request additional information from the reporter and may interview witnesses.

D. Upon completion of the investigation, appropriate corrective action will be taken if the allegations are substantiated.

E. The reporter will be informed of the outcome of the investigation to the extent appropriate, consistent with privacy and legal considerations.

V — Protection from Retaliation

A — No Retaliation

The Corporation prohibits retaliation against anyone who, in good faith, reports a concern under this policy or participates in an investigation. Retaliation includes, but is not limited to:

• Termination or discharge;
• Demotion or denial of promotion;
• Reduction in salary or benefits;
• Negative performance evaluation;
• Reassignment to a less desirable position;
• Harassment, discrimination, or intimidation; and
• Any other adverse action taken because of the report.

B — Reporting Retaliation

If you believe you have been retaliated against for making a report under this policy, immediately report the retaliation to the Chair of the Board of Directors or another Board member.

C — Consequences of Retaliation

Any Director, officer, employee, or volunteer who engages in retaliation will be subject to disciplinary action, up to and including removal from their position or termination of employment.

VI — Good Faith Requirement

A. This policy is intended to protect individuals who make reports in good faith. A report is made in good faith when the reporter genuinely believes the information reported is accurate and indicates a potential violation.

B. This policy does not protect individuals who knowingly make false or malicious reports. Any individual who makes a report that is determined to be intentionally false or malicious will be subject to disciplinary action.

VII — Confidentiality

A. The Corporation will treat all reports and investigations as confidentially as possible, consistent with the need to conduct an adequate investigation and take appropriate corrective action.

B. Information about reports and investigations will be shared only with those who have a legitimate need to know.

C. The identity of the reporter will be protected to the extent possible, consistent with legal requirements and the need for an effective investigation.

VIII — Record Keeping

The Corporation will maintain records of all whistleblower reports and investigations in accordance with its Document Retention Policy. These records will be kept confidential and separate from personnel files.

IX — Policy Administration

A. The Board of Directors is responsible for overseeing the administration of this policy.

B. This policy will be distributed to all Directors, officers, employees, and volunteers.

C. The Board will review this policy annually and make any necessary updates.