Whistleblower Policy

Names of individuals will remain confidential.

There is no guarantee that any of the individuals listed will be contacted if the need arises. The primary goal is to provide names for consideration. If the leave occurs and a prolonged search is incurred, the ISUAA Board and the Office of the ISU President might consider appointing an interim to carry out the duties of the position until a permanent hire is named and on board.

Short-term leave coverage

If the need arises for short-term coverage of the Talbot Endowed ISUAA President and CEO, the ISUAA Board, with leadership from the current ISUAA Board chair, will work with the president of the university to appoint an individual to fulfill the duties until the employee returns. Adopted by the ISU Alumni Association Board of Directors on May 21, 2010 and Feb. 15, 2019.

WHISTLEBLOWER POLICY

Purpose:

To maintain public trust and accountability which are essential to the success of the Iowa State University Alumni Association (“ISUAA”), a method is provided to enable employees, officers, directors or volunteers of the ISUAA to report “Suspected Wrongdoing,” which is defined to mean: 1. the financial management of the Association, its assets, internal controls and auditing or financial reporting matters;

2. compliance with ISUAA Policies or Iowa State University

Policies;

3. compliance with applicable federal, state, or local law and regulations; or 4. any action which would discredit the ISUAA.

Procedure:

Employees shall report concerns, preferably in writing, to their supervisors. Alternatively, an employee, officer, director, volunteer or vendor may report Suspected Wrongdoing as follows: 1. Any individual may submit an anonymous complaint, preferable in writing, of Suspected Wrongdoing regarding any ISUAA employee, officer, or director of the ISUAA in the following manner: a. by contacting one of the following by email or phone: • Talbot Endowed ISUAA President and CEO • ISUAA Chair of the Board of Directors • Chair-elect of the ISUAA Board of Directors • Chair of the ISUAA Audit Committee

b. by contacting the Iowa State University Compliance and Ethics Hotline (515) 294-7119 or

c. by accessing the Compliance and Ethics website, which is listed on the ISU homepage index under “C”, “Confidential Hotline”.

2. An anonymous complaint must provide sufficient detailed information identifying the activity and individual to initiate an investigation into Suspected Wrongdoing. 3. After an anonymous complaint is submitted, an email outlining the Suspected Wrongdoing will be sent to the

ISUAA Audit Committee chair, the Chair of the Board of Directors, and Talbot Endowed ISUAA President and

CEO. In the event the Suspected Wrongdoing involves any of these three individuals, then that individual will not receive such an email.

4. Investigation involving Suspected Wrongdoing as set forth in A(2)-(4) shall be conducted by the ISUAA Audit

Committee Chair, the Chair of the Board of Directors and

Talbot Endowed ISUAA President and CEO subject to the participation limitation in B(3). 5. Should the Suspected Wrongdoing involve any financial matter set forth in A(1):

a. The Chair of the Audit Committee, in consultation with the Chair of the Board of Directors, will initiate an investigation of the Suspected Wrongdoing. The Chair of the Audit Committee may appoint an appropriate individual to investigate the matter on behalf of the Audit Committee and Board of Directors. In the event the Suspected Wrongdoing involves the Talbot Endowed ISUAA President and CEO, the Chair of the Audit Committee will work with the Chair of the Board of Directors to determine the investigation process.

BOARD POLICIES – GENERAL CONTINUED

b. A written report of the findings of any such investigation of Suspected Wrongdoing pursuant to this policy will be forwarded to all members of the Audit Committee. If the Audit Committee determines further investigation is required, the matter will be referred to the Board of Directors.

6. The Chair of the Audit Committee shall acknowledge receipt of the complaint to the person who make the complaint if sent on other than anonymous terms. 7. A complaint which involves any conduct or action of

Suspected Wrongdoing that is not covered in B(5) will receive immediate attention and, if the complaint appears to be reasonably substantiated, and investigation will commence as soon as practical. 8. Discussions and documentation regarding the reports will be kept in strict confidence, consistent with the need to conduct and adequate investigation. Further, confidentiality will be adhered to as permitted by A(2)(3).

9. The custodian of records arising from any complaint of

Suspected Wrongdoing, any investigation materials, any report of findings or any other documents relating to in any manner to such Suspected Wrongdoing shall be:

Director of Office Operations. In the event the Director of

Operations is the subject of Suspected Wrongdoing, then the Chair of the Board of Directors shall select a person in senior management of ISUAA to serve as custodian of such records. Such documents shall be kept a security level directed by Iowa State University. 10. The ISUAA will take prompt and appropriate corrective action when necessary to ensure compliance with the financial, legal, and ethical requirements relating to a reported matter. 11. Complaints received through this procedure that do not rise to the level of Suspected Wrongdoing will be referred to the appropriate supervisor, Director of Office

Operations, or Human Resources as appropriate. The

Chair of the Audit Committee shall acknowledge receipt of such a complaint.

Protection:

1.No retaliatory action of adverse employment consequences will be taken against an employee for reporting, in good faith and with a reasonable belief, any Suspected Wrongdoing by another employee, officer, or director of the ISUAA.:

2.Any person who receives services from or provides services to the ISUAA who submits a complaint of Suspected Wrongdoing with a good faith belief the information disclosed constitutes a violation, will not suffer adverse service consequences. 3.Any employee, officer, director, volunteer or vendor who retaliates against a person who has reported Suspected Wrongdoing as set forth in B(2), will be subject to disciplinary action up to and including termination or removal.

4.Any complaint of Suspected Wrongdoing that, through the investigation procedure set forth above, is determined to be unsubstantiated and determined to have been filed made recklessly, maliciously or with the knowledge that the allegations were false, be treated as a serious disciplinary offense. This policy and its procedures are subject to change at the discretion of the ISUAA Board of Directors.

Adopted by the ISU Alumni Association Board of Directors May 21, 2010. Amended by the ISU Alumni Association Board of Directors May 15, 2020.