To help ensure that the Rainforest Alliance complies with the highest standards of financial reporting and lawful and ethical behavior, the Board of Directors established the following procedure for the reporting of illegal or unethical conduct in connection with the Rainforest Alliance's finances or other aspects of its operations, and the retention and treatment of such complaints, including confidential, anonymous submissions received from employees.
Should any person know or have a reasonable belief that anyone associated with the Rainforest Alliance plans to engage or has engaged in illegal or unethical conduct in connection with the finances or other aspect of the Rainforest Alliance's operations, that person should immediately file a complaint with the General Counsel (a "Complaint"). Employees of the Rainforest Alliance may submit Complaints on a confidential, anonymous basis. If the Complaint concerns the General Counsel or the complainant is not comfortable reporting to the General Counsel, then the complainant should notify the Chair of the Audit and Risk Committee or another Director 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.
All Complaints shall be reported to the Chair of the Audit and Risk Committee, or, if the Chair of the Audit and Risk Committee is the subject of the Complaint, to another member of the Audit and Risk Committee, prior to its next regularly scheduled meeting. In appropriate circumstances, the General Counsel or the Chair of the Audit and Risk Committee or other Director may report a Complaint to the Board Chair. Reports to the Chair or other Audit and Risk Committee member or to the Board Chair will include a copy of the Complaint, its date, nature and source (unless the complainant is an employee who has requested confidentiality and/or anonymity), how it was communicated, whether the General Counsel or Director regards the Complaint as credible, and proposals to address it. The Chair or other Audit and Risk Committee member will promptly report the Complaint to the full Committee, except that the Complaint will not be shared with an individual who is the subject of the Complaint. Likewise, if a Complaint is reported to the Board Chair, she or he will promptly report the Complaint to the full Board, except to any individual who is the subject of the Complaint. All credible allegations will be followed up promptly, with further investigation conducted if needed to resolve disputed facts. In conducting its investigations, the Rainforest Alliance will respect an employee's request for confidentiality and/or anonymity and will strive to keep the identity of other complainants as confidential as possible, consistent with the need to conduct an adequate review and investigation.
The Audit and Risk Committee will inform the Board if any Complaint is confirmed, or if the Committee otherwise believes that the Board should be made aware of the situation. The Audit and Risk Committee will have ultimate authority over the treatment of any Complaints reported to it, subject to the Board's oversight. The Audit and Risk Committee or, in the case of Complaints reported to the full Board, the Board, will ensure that records of all Complaints are maintained in accordance with the Rainforest Alliance content management policy.
The Rainforest Alliance will take appropriate action in response to any Complaint, including, but not limited to, disciplinary action (up to and including termination of employment) against any person who, in the Rainforest Alliance's assessment, has engaged in misconduct, and reporting such misconduct to the relevant civil or criminal authorities as required by law.
The Rainforest Alliance will not knowingly, with the intent to retaliate, take any action harmful to any person, including interference with lawful employment or livelihood, for:
- reporting a Complaint in good faith pursuant to this policy or to law enforcement officers, governmental agencies or bodies, or persons with supervisory authority over the complainant;
- providing in good faith information regarding a Complaint to law enforcement officers, governmental agencies or bodies, or persons with supervisory authority over the complainant, or otherwise assisting in any investigation conducted by the Rainforest Alliance; or
- otherwise participating or assisting in a proceeding filed or about to be filed.
An individual who deliberately or maliciously provides false information may be subject to disciplinary action, up to and including termination of employment.
233 Broadway, 28th Floor
New York, New York 10279
Telephone: (212) 677-1900
Chair of Audit and Risk Committee
Board of Directors