Whistleblower Policy

To help ensure that Rainforest Alliance, Inc. (the “Rainforest Alliance”) complies with the highest standards of financial reporting and lawful and ethical behavior, the Board of Directors of the Rainforest Alliance (the “Board”) has established the following procedures for the reporting of illegal or unethical conduct in connection with the Rainforest Alliance’s finances, corporate policies or other aspects of its operations, and the retention and treatment of such complaints, including confidential, anonymous submissions received from directors, officers, employees and volunteers who provide substantial services to the Rainforest Alliance (who are referred to in this policy as “volunteers”). The General Counsel of the Rainforest Alliance (the “General Counsel”) is hereby designated to administer this policy. This policy must be distributed to all directors, officers, employees and volunteers of the Rainforest Alliance.

Procedure for Reporting Complaints

Should any director, officer, employee, or volunteer of the Rainforest Alliance have a concern regarding any action or suspected action taken by or within the Rainforest Alliance that is illegal, fraudulent, or in violation of any adopted corporate policy, that person should immediately submit a complaint (a “Complaint”) to the General Counsel. Individuals may identify themselves in a Complaint or may submit Complaints on a confidential, anonymous basis, either orally or in writing. If a Complaint concerns the General Counsel or the complainant is not comfortable reporting to the General Counsel, then the complainant should submit the Complaint to the Chair of the Audit and Risk Committee of the Board or another member of the Audit and Risk Committee instead. Issues arising under the Rainforest Alliance’s equal employment opportunity policy, including the policy against harassment, employee benefit policies and issues generally handled by individuals responsible for the Rainforest Alliance’s personnel practices and procedures are not covered by this policy. Mechanisms for resolving such issues are addressed in separate procedures.

Investigation

The General Counsel or the Chair of the Audit and Risk Committee shall cause all Complaints to be investigated, unless he or she believes that the Complaint was not made in good faith or unless the Complaint was made anonymously and does not contain sufficient information to conduct an investigation. The Chair of the Audit and Risk Committee may, at his or her discretion, direct any investigation to be conducted by others, such as outside legal, accounting, or other advisors. Investigations will be conducted with as much confidentiality as is possible and practical. However, in all cases the Rainforest Alliance will use best efforts to act with discretion.

Review

After the investigation is complete, the Audit and Risk Committee will receive a written report of the investigation, its findings and any action taken or proposed. The Audit and Risk Committee will inform the Board if any Complaint is confirmed to have merit or if the Committee otherwise believes that the Board should be made aware of the situation. The Audit and Risk Committee will ensure the appropriate resolution of any Complaints reported to it, subject to the Board's oversight. The Audit and Risk Committee will use best efforts to ensure that records of all Complaints are maintained in accordance with the Rainforest Alliance’s Records Retention and Management policy.

Protection under Policy

No director, officer, employee, or volunteer of the Rainforest Alliance who in good faith reports any action or suspected action taken by or within the Rainforest Alliance that he or she perceives to be illegal, fraudulent, or in violation of any adopted corporate policy shall suffer intimidation, harassment, discrimination or other retaliation or, in the case of employees, adverse employment consequences. The Rainforest Alliance will impose disciplinary measures against anyone who threatens or retaliates against a person for making a Complaint in good faith pursuant to this policy or for participating in an investigation. However, any director, officer, employee or volunteer who deliberately or maliciously provides false information may be subject to disciplinary action, up to and including termination of employment.

No Contract

This policy cannot be viewed as creating a promise or contract by the Rainforest Alliance, and it may be amended by the Rainforest Alliance at any time without prior notification. Employment at the Rainforest Alliance in the United States is at-will, and nothing in this policy should be interpreted as in any way limiting this at-will relationship.

Contacts

Rainforest Alliance
233 Broadway, 28th Floor
New York, New York 10279
Telephone: +1 (212) 677-1900

General Counsel

Leslie Park

Chair of Audit and Risk Committee

Annemieke Wijn
Board of Directors