LHM Code of Conduct | Page 35

Section 7 : Our Responsibility for Compliance 29
We have a process for responding to reported concerns .
The Anonymous Reporting Service website and toll-free numbers are available 24 hours a day , seven days a week for use by Company employees . Trained professionals answer all calls to the reporting hotline . All complaints are promptly sent to the Anonymous Reporting Committee .
All reports will be investigated and appropriate action will be taken . We enforce a strict “ no retaliation ” policy that protects anyone reporting a concern in good faith . Those who retaliate are subject to disciplinary action . The following chart outlines the reporting process :
A live operator
You report a concern to the Lighthouse Services hotline .

1
will take down the details and help identify the issue . You do not have to give your name if you choose .

2
Lighthouse Services sends a report to the Anonymous Reporting Committee .

3
The investigator
The Anonymous Reporting Committee assigns a team to investigate .

4
If you provide your name , an investigator will contact you and attempt to resolve the situation .

5
may interview you and other employees and / or review Company records and other information .

6
If there has been a violation of a Company policy , the investigator will work with HR / P & C / Legal to decide what action ( s ) to take next .

7
If there is no violation , the case will be closed . If the investigation uncovers an issue with the process , policy , or procedure ,

8 it will be addressed .
There will be no retaliation against anyone who makes a report in good faith , even if no violation has actually occurred .

9