Whistleblower Protection Policy
Scope and Purpose
The purpose of this Policy is to encourage all individuals to disclose any wrongdoing that may adversely impact the Company, the Company’s policyholders, employees, or the communities in which the Company does business. This Policy also outlines the individuals responsible for accepting reports and initiating the investigative procedures as well as ensuring that confidence and protection is provided to the individual making the report.
Definitions
Whistleblower – any person including employees, directors, officers, field representatives, customers, or community members who reports information regarding an actual, suspected, or anticipated wrongdoing within the Company.
Wrongdoing – examples of wrongdoing include, but are not limited to, financial fraud, violations of insurance laws and regulations, falsification of Company documents, unethical behavior or practices pertaining to financial or other business relationships with suppliers, customers, or competitors that could impair judgment on Company matters, endangerment to public safety, and mismanagement of Company resources. Wrongdoing does not include personnel issues that would typically be reported to and handled by the Company's Human Resources Director or any other issues that are not covered by this definition. Those kinds of issues should be reported to your manager and/or Human Resources for handling as provided in the Employee Handbook. If you do not feel comfortable discussing the issue with your manager, you should report this issue to your manager’s manager or to Human Resources.
General Guidance
This Policy presumes that individuals will act in good faith and will not make false accusations. An individual who knowingly makes false statements or disclosures may be subject to disciplinary actions.
Whenever possible, employees should try to resolve issues of wrongdoing by reporting them directly to their supervisor or to the next level of management as needed. However, if the employee does not feel comfortable reporting to a supervisor or does not feel the complaint is being handled appropriately, the employee should report the issue to the Compliance Manager. If the employee does not feel comfortable reporting this to someone within the Company, they may report directly to a member of the Audit Committee or the External Audit Partner. The contact information for these individuals will be distributed to employees annually.
Any individual wishing to make a confidential and anonymous submission according to this Policy should address his or her concerns in writing and forward the same to the Director of Internal Audit, or other appropriate individual, in a sealed envelope marked with:
“CONFIDENTIAL”
Compliance Manager
Pharmacists Mutual Insurance Company
808 US Hwy 18 W
PO Box 370
Algona, IA 50511
Phone: 800.247.5930 ext. 7442
In order to remain confidential and anonymous, the individual should not include his or her name or return address on the envelope or written submission. Additionally, the individual should type the submission. The submission should be factual rather than speculative and should contain as much specific information as possible to allow for a proper assessment.
Procedures for Handling Reports
All reports made under this Policy will be handled promptly. Reports made internally without initial resolution by the manager will be reported to the Compliance Manager for investigation. Supervisors should bring all issues reported under this Policy, including those resolved within the team, to the attention of the Compliance Manager. The Compliance Manager will report all matters disclosed under this Policy to the Audit Committee. In addition, any matters involving PMC Advantage Insurance Services, Inc. will also be reported to that Audit Committee. The External Audit Partner should forward all complaints to the Audit Committee Chairperson and/or the Compliance Manager for investigation.
The Audit Committee Chairperson and the Compliance Manager have the responsibility to ensure that complaints which are not required to be reported pursuant to this Policy shall be handled in the appropriate fashion and shall not be referred to the Audit Committee. By way of example only, complaints regarding age, race or sexual discrimination and health or safety violations are outside the scope of this policy and should be handled by the Human Resource Department.
The Compliance Manager and/or the Audit Committee will consider each matter reported to it and, as appropriate, investigate the complaint. The Committee may engage the auditors or other professionals for their assistance. The Audit Committee may require changes to financial statements, accounting procedures, and/or internal control procedures.
A report of findings and recommendations will be prepared based on the results of the investigation. If the investigation shows fraud or unethical behavior was not present, the name of the employee involved will not be reported to the Audit Committee. However, if an Officer (Vice President or above) is being investigated, the name of the Officer will be reported to the Audit Committee regardless of the investigation findings. Copies of the report will be provided to the Audit Committee. If the findings indicate the complaint has validity, the Audit Committee will discuss the necessary actions with management, which could include disciplining the responsible person(s) and/or establishing new processes to prevent further violations. Any intentional acts to defraud the Company or to create misleading financial statements may subject the perpetrator to discipline up to and including termination. In the case of Directors, the Audit Committee will recommend the appropriate disciplinary action to the Board of Directors. PMIG reserves the right to notify law enforcement of any wrongdoing that may expose the Company or any individual to criminal liability.
Confidentiality and Protection
All reasonable steps will be taken to protect the identity of the whistleblower for complaints made under this Policy. In addition, PMIG will not discharge, demote, threaten, harass, discriminate against, or tolerate any of the foregoing, in regards to the whistleblower. Claims of acts of retaliation should be submitted to the Compliance Manager or Audit Committee Chairperson who will initiate a confidential investigation.
Access to Reports and Records
All reports and records associated with complaints are considered confidential information and access will be restricted to members of the Audit Committee, the Compliance Department, legal counsel, and employees or third parties involved in investigating a complaint. Access to reports and records may be granted to other parties at the discretion of the Audit Committee.
Retention of Records
The Compliance Manager shall retain for a period of seven years all records relating to complaints brought under this Policy.
Compliance Manager
Steven Courtney ext. 7442
Last Review – April 2024