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Whistleblower Policy

Lifeworks requires that all personnel will, in connection with all Lifeworks matters, observe high standards of business and personal ethics, practice honesty and integrity, comply with all applicable laws and regulations, comply with all Lifeworks policies, and report violations or suspected violations in accordance with this whistleblower policy.

Lifeworks strives to have an open door policy and encourages all personnel to share their questions, concerns, suggestions, or complaints regarding the organization (“issues“) with those within the organization who can address them properly, on the basis set out in this policy. All Lifeworks personnel are encouraged to ask questions if they are unsure about how to proceed or whether conduct violates the law or Lifeworks policies.

It is the policy of Lifeworks that no Lifeworks personnel who, in good faith, report a violation of applicable laws, regulations, or Lifeworks Policies in accordance with this policy shall suffer harassment, retaliation, or adverse employment consequences as a result of making such a report. Any Lifeworks personnel who so retaliates against anyone who, in good faith, has reported an issue under this policy is subject to discipline up to and including termination of employment or relationship with Lifeworks.

It is further the policy of Lifeworks that appropriate Lifeworks authorities will take prompt action to investigate and resolve any issues reported under this policy on a timely basis.

Rights & Responsibilities

Compliance Authorities

The President and CEO will act as chief compliance officer for Lifeworks and will have overall responsibility for the implementation and administration of this policy. The CEO may delegate responsibilities under this policy to a compliance officer and/or compliance department, who will report to the CEO and/or the Lifeworks Board of Directors (as described below) with respect to matters relating to this policy.

The chief compliance officer (and/or his/her designee) will annually report compliance activity to the Audit and Investment Committee of the Lifeworks Board of Directors for presentation to the full Board. The Audit and Investment Committee may, in its discretion, report any matters subject to this policy to the full Board or Directors.

Reporting of Issues

Internal Channels. Lifeworks Personnel are encouraged to report issues through internal channels, as follows:

  • An employee or volunteer should first present an issue to his/her supervisor. However, if the employee or volunteer is not comfortable speaking with the supervisor about the issue or is not satisfied with the supervisor’s response, the employee or volunteer is encouraged to present the issue to someone in the human resources department, the compliance department, or anyone in management.
  • An officer (other than the CEO) should first present an issue to the CEO. However, if the officer is not comfortable speaking with the CEO about the issue or is not satisfied with the CEO’s response, the officer is encouraged to present the issue to the Chair of the Board.
  • The CEO or a member of the Board or Board Committee should present an issue to the Chair of the Board. However, if the CEO or member is not comfortable speaking with the Board Chair about the issue or is not comfortable with the Board Chair’s response, the member is encouraged to speak with anyone on the Board whom he/she is comfortable in approaching, or to directly contact the organization’s outside legal counsel, whose contact information can be obtained from the CEO.
  • As a last resort, any Lifeworks personnel may report an issue directly to the CEO, a member of the Board of Directors, or the organization’s outside legal counsel.

Whistleblower Hotline. Alternatively, Lifeworks Personnel may report issues at any time to the Lifeworks whistleblower hotline, staffed by an independent whistleblower hotline company retained to anonymously and confidentially accept messages about issues relating to Lifeworks. Issues can be communicated to the Lifeworks whistleblower hotline as follows:

  • By leaving a message at the following toll-free telephone number: 1-877-767-7781. Callers to this number will be assigned a five-digit case number for the reported issue. Callers should record the case number at the time of the call because the case number cannot be recovered after the call has ended. The hotline company is responsible for transcribing the caller’s message, deleting it from its system and sending the message to appropriate authorities at Lifeworks. A caller may check the status of his/her reported issue at any time by calling the above number and entering the assigned five digit case number.
  • By sending an email to lifeworks@getintouch.com. The hotline company is responsible for removing the origination address and forwarding just the content of the message to appropriate authorities at Lifeworks.

Lifeworks personnel are encouraged to direct questions to supervisors, managers, and officials (on the basis described below) if they are unsure about how to proceed or whether specific conduct violates the law or Lifeworks policies.

Handling and Reporting Issues

The chief compliance officer (or his/her designee) is responsible for investigating and resolving all reported issues, except if the issue involves:

  • the CEO, the Board (other than the CEO) will be responsible for investigating and resolving the issue;
  • a Board member, the remainder of the Board will be responsible for investigating and resolving the issue; and
  • the CEO and one or more members of the Board, the remaining members of the Board will be responsible for investigating and resolving the issue;
  • Matters involving corporate accounting practices, internal controls, or auditing matters (other than minor matters involving no alleged misconduct or potentially material financial implications), the Audit and Investment Committee of the Board of Directors will be responsible for investigating and resolving the issue.

The person(s) responsible for investigating and resolving a reported issue will:

  • Promptly and thoroughly investigate the matter made the subject of the reported issue;
  • Acknowledge receipt of the reported issue to the individual reporting it (if his/her identity is known;
  • Involve other Lifeworks personnel, as appropriate, to assist in the investigation and resolution of the issue;
  • Seek the advice and counsel relative to legal matters;
  • Institute appropriate measures, if warranted, to correct and resolve the matter made the subject of the issue; and
  • Document the investigation and resolution of the issue

Requirement of Good Faith

Anyone filing a complaint concerning a violation or suspected violations must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Lifeworks personnel are not free to make statements or disclosures knowing they are false or that they are in reckless disregard of the truth. Any allegations that prove not to be substantiated and which were maliciously made or knowingly false will be viewed as a serious disciplinary offense.

Confidentiality

All Lifeworks personnel involved in the investigation and resolution of any reported issues under this policy will (to the greatest extent consistent with a thorough investigation, the discharge of legal obligations, and the proper resolution of the issue) maintain in confidence the identity of the person reporting the issue and the subject of the reported issue.