2022 Code of Ethics - Page 12

When an employee has a concern about something that may contradict our Code we encourage them to Speak Up , Speak Out , and report it . BBNC maintains an open-door policy for employees to ask questions or raise concerns regarding BBNC ’ s policies , subsidiary policies , the law , or ethical conduct . Persons who speak up in good faith to protect our companies will be protected in return .
BBNC ’ s non-retaliation policy reinforces our long-standing commitment to a safe reporting environment that is free of fear , bullying and other negative consequences . BBNC has zero tolerance for retaliation and activities that impact good-faith reporting . Anyone engaging in retaliatory behavior is subject to disciplinary action , up to termination .
If you have a question or concern , our open-door policy provides multiple channels for employees , who are acting in good faith , to report concerns without fear of retaliation .
ETHICS HOTLINE : HOW TO FILE A REPORT
BBNC employs a third-party hotline service called Ethical Advocate . It is available to employees , vendors and clients .
You may create a secure login managed by Ethical Advocate to file a report online or via telephone . The login allows you to access communications , including requests for additional information , related to the report .
All reports will be reviewed and assigned to HR , Compliance , and / or Legal , as appropriate . If warranted , an investigation will be undertaken .
Once the review or investigation is complete , the report will be closed . While we cannot share the results of a review or investigation , we will share information to the extent possible with relevant parties .
REVIEW & INVESTIGATIONS
BBNC recognizes the importance of a standardized method to detect , prevent , and correct incidents , allegations , reports and suspicions ( collectively ‘ incidents ’) of potential misconduct and violations of law , regulations , or written standards .
Incidents of potential misconduct and violations of law , regulations , or written standards must be reported , triaged , investigated , where warranted , and resolved by qualified and trained investigators . BBNC is committed to full cooperation with any government agencies conducting a review or investigation of an incident of potential misconduct or violations of law , regulations , or written standards .
INTERFERENCE WITH AN AUDIT
BBNC is regularly audited in a number of areas . You are expected to fully cooperate with any audit and readily provide information requested by auditors . All information provided must be unaltered and accurate .
BBNC COMPLIANCE DEPARTMENT
To contact the BBNC Compliance Department :
907.278.3602 Compliance @ bbnc . net
111 W . 16th Avenue , Suite 400 Anchorage , Alaska
99501
1.866.513.7078 info . bbnc . net
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