Codes of Ethics and Whistleblower Policy

Purpose

3 Times As Many, Inc. requires and encourages Directors, officers and employees to observe and practice high standards of business and personal ethics in the conduct of their duties and responsibilities.  The employees and representatives of the corporation must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations.  It is the intent of 3 Times As Many, Inc. to adhere to all laws and regulations that apply to the corporation. The underlying purpose of this policy is to support the

corporation’s goal of legal compliance.  The support of all corporate staff is necessary in achieving compliance with various laws and regulations.

Reporting Violations

If any director, officer, staff or employee reasonably believes that some policy, practice, or activity of 3 Times As Many, Inc. is in violation of law, a written complaint must be filed by that person with the vice president or the Board president.

Acting in Good Faith

Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation.  Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false shall be subject to civil and criminal review.

Retaliation

Said person is protected from retaliation only if she/he brings the alleged unlawful activity, policy, or practice to the attention of 3 Times As Many, Inc. and provides 3 Times As Many, Inc. with a reasonable opportunity to investigate and correct the alleged unlawful activity.  The protection described below is only available to individuals that comply with this requirement.

3 Times As Many, Inc. shall not retaliate against any director, officer, staff or employee who in good faith, has made a protest or raised a complaint against some practice of 3 Times As Many, Inc. or of another individual or entity with whom 3 Times As Many, Inc. has a business relationship, on the basis of a reasonable belief that the practice is in violation of law, or a clear mandate of public policy.

3 Times As Many, Inc. shall not retaliate against any director, officer, staff or employee who discloses or threaten to disclose to a supervisor or a public body, any activity, policy, or practice of 3 Times As Many, Inc. that the individual reasonably believes is in violation of a law, or a rule, or regulation mandated pursuant to law or is in violation of a clear mandate of public policy concerning the health, safety, welfare, or protection of the environment.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously.  Reports of violations or suspected violations shall be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

The Board president or vice president shall notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days.  All reports shall be promptly investigated by the Board and its appointed committee and appropriate corrective action shall be taken if warranted by the investigation.

This policy shall be made available to all Directors, officers, staff or employees and they shall have the opportunity to ask questions about the policy.