This policy has been put in place to ensure all concerns raised regarding any misconduct or improper state of affairs or circumstances in relation to Axion Biosystems, Inc.’s business are dealt with effectively, securely, and appropriately. The Company encourages the reporting of any instances of suspected unethical, illegal, corrupt, fraudulent, or undesirable conduct involving Axion’s business and provides protections and measures to individuals who make a disclosure in relation to such conduct without fear of victimization or reprisal.
Reportable Conduct
You may make a report or disclosure under this policy if you have reasonable grounds to believe that a Company director, officer, employee, contractor, supplier, consultant, or other person who has business dealings with Axion Biosystems, Inc. has engaged in conduct (Reportable Conduct) which is:
- Dishonest, fraudulent or corrupt
- Illegal (such as theft, dealing in or use of illicit drugs, violence or threatened violence and criminal damage to property)
- Unethical including any breach of the Company’s policies such as the Code of Conduct; Oppressive or grossly negligent
- Potentially damaging to the Company, its employees or a third party; Misconduct or an improper state of affairs
- A danger or represents a danger to the public or financial system; Harassment, discrimination, victimization or bullying.
For the avoidance of doubt, Reportable Conduct does not include personal work-related grievances. A personal work-related grievance is a grievance about any matter in relation to an employee's current or former employment, having implications for that person personally and that does not have broader implications for the Company. Examples of personal work-related grievances are as follows:
- An interpersonal conflict between the staff member and another employee
- A decision relating to the engagement, transfer or promotion of the employee; A decision relating to the terms and conditions of engagement of the employee
- A decision to suspend or terminate the employment of the employee, or otherwise to discipline the employee
Personal work-related grievances should be reported to your manager and/or HR.
Internal Reporting
You may disclose any Reportable Conduct to:
- HR
- Chief Executive Officer or Chief Financial Officer
Anonymity
When making a disclosure, you may do so anonymously. It may be difficult for the Company to properly investigate the matters disclosed if a report is submitted anonymously and therefore the Company encourages you to share your identity when making a disclosure, however you are not required to do so.
Investigation
Axion Biosystems, Inc. will investigate all matters reported under this policy as soon as possible after the matter has been reported. The Company will investigate the matter and, where necessary, appoint an external investigator to assist in conducting the investigation. All investigations will be conducted in a fair, independent, and timely manner and all reasonable efforts will be made to preserve confidentiality during the investigation.
Protection of Whistleblowers
Axion Biosystems, Inc. is committed to ensuring that any person who makes a disclosure is treated fairly and does not suffer retaliation and that confidentiality is preserved in respect of all matters raised under this policy.
