It is the policy of AFS-USA, Inc. (“AFS”) to observe high ethical standards in all its activities. AFS seeks to ensure that all transactions and corporate assets are properly accounted for and that all audits are thorough and complete. It is also important to AFS that it maintains the confidence of employees, customers, vendors and the public in the quality of AFS’s accounting and public reporting. AFS places a high priority on the business of AFS being conducted in compliance with all state, federal and applicable foreign laws concerning its operations, and consistent with the highest ethical standards.
In order to help accomplish these objectives, AFS has established procedures for the confidential receipt, retention and treatment of complaints and concerns about accounting, internal accounting controls, auditing, financial and other matters related to the conduct of business, such as business relationships with vendors, customers, government officials, volunteers, and affiliated organizations (collectively “business complaints”). Business complaints include not only those activities that could involve AFS in an improper practice or violation of law, but also those that have even the appearance of impropriety, including, without limitation, the following:
- fraud or deliberate error in the preparation, evaluation, review or audit of any financial statement and all regulatory filings of AFS;
- fraud or deliberate error in the recording and maintaining of financial records of AFS;
- deficiencies in or noncompliance with internal accounting controls;
- misrepresentation or false statement to or by a senior officer or accountant regarding a matter contained in the financial records, financial reports, or audit reports of AFS; or
- deviation from full and fair reporting of AFS’ financial condition.
These procedures apply to business complaints submitted by employees and non-employees of AFS. Business complaints do not include personnel complaints. Personnel complaints are those concerns that are related to employment at AFS, including matters related to occupational safety and health, promotions, age, sex, race or sexual orientation discrimination or harassment. Personnel complaints should be reported to the employee’s immediate supervisor and/or the Human Resources Department. Business complaints also do not include participant-related complaints, which are addressed through the Participant Support and Legal departments of AFS.
Submission of Business Complaints
The procedures detailed below relate to the submission of business complaints. Any persons wishing to report such business complaints can be assured the situation will be handled with the highest level of anonymity and confidentiality. In addition, employees reporting questionable accounting or auditing matters will be protected from retaliation for making such complaints.
Both employees and non-employees may submit complaints by sending an email to [email protected]. Any person submitting a business complaint is encouraged to provide as much detail as possible regarding the subject matter of the complaint, as the ability to investigate and to rectify any problem will depend largely on the quality and specificity of the information provided in the complaint.
The person communicating a business complaint may do so anonymously. If the business complaint is made anonymously, AFS will not make any special effort to identify the person making the communication. All business complaints submitted will be treated as confidentially as circumstances permit. If the person communicating the business complaint identifies himself or herself, AFS will not disclose the person’s identity without his or her permission or unless required by law to do so. Information contained in business complaints may be summarized, abstracted and aggregated for purposes of analysis and investigation.
Retention of Business Complaints
All records of business complaints received by AFS will be preserved for 10 years in the following manner:
- The Senior Management team will have custody of the records of business complaints.
- After the 10-year retention period, the records of business complaints may be disposed.
- Any information developed while responding to a business complaint or investigations regarding such business complaint will be documented and retained as confidential information pursuant to AFS’ document retention policy.
Investigation and Reporting of Business Complaints
Normally, business complaints will be investigated by the Senior Management team or a designee. The Senior Management team or a designee will immediately inform the Executive Team, who in turn will inform the Chair of the Finance and Audit Committee or the Board Treasurer, if a business complaint has been received or been notified of a business complaint that involves matters that are material to the financial statements, involves accounting or auditing procedures or a corporate officer.