Employees who observe, learn of, or, in good faith, suspect a violation of the Code of Conduct of the Company ("Suspected Code Violations") should immediately report the violation in accordance with the following procedures.
Employees who observe, learn of, or, in good faith, suspect a violation of the Code of Conduct of the Company ("Suspected Code Violations") should immediately report the violation in accordance with the following procedures. Similarly, any employee or other person who has good faith complaints or concerns regarding accounting, internal accounting controls or auditing matters ("Accounting Concerns") should communicate those complaints or concerns in accordance with the following procedures. As described below, employees who report Suspected Code Violations or Accounting Concerns in good faith will not be subject to retaliation of any kind.
Procedure for Reporting Code Violations
Any person who has knowledge of a suspected Code Violation should file a complaint by contacting:
Complaints may be made on a confidential or anonymous basis. When making a complaint, the employee should provide as much specific information as possible, including names, dates, places, events, and an explanation of why the employee believes the incident is a Code Violation.
Any person that has knowledge of an Accounting Concern should file a complaint by contacting:
Accounting Concerns directed by employees may be made on a confidential or anonymous basis. When voicing a concern, the reporting person should be as clear as possible concerning the exact nature of the concern and should provide as much specific information as possible, including names, dates, places, events, and an explanation of why the employee believes the matter is an Accounting Concern.
Accounting Concerns which should be reported in accordance with these procedures include, without limitation, the following:
The General Counsel shall cause to be maintained a log of all reports of Suspected Code Violations and Accounting Concerns, tracking their receipt investigation and resolution.
Suspected Code Violations and Accounting Concerns which are reported pursuant to these procedures will be investigated and addressed promptly and will be treated confidentially to the extent possible, consistent with the need to conduct an adequate review. Records relating to complaints received pursuant to these procedures and related investigatory records will generally be retained for a period of five years following the conclusion of the investigation. Such records may be kept electronically.
SEI prohibits any form of retaliation against employees who, for lawful purposes, makes a complaint regarding a Suspected Ethics Violation. SEI also prohibits any form of retaliation against employees who provide information, cause information to be provided, or assist in an investigation conducted by the Company or any governmental body, regarding a possible violation of any law or regulation relating to fraud or any rule or regulation of the United States Securities and Exchange Commission, or who file, cause to be filed, or assist, participate or give testimony in any proceeding relating to an alleged violation of any such law, rule or regulation.
All managers are responsible for ensuring adherence to this non-retaliation policy. In addition, each manager is responsible for communicating this policy to employees under his or her supervision and for supporting programs and practices designed to develop understanding of, commitment to and compliance with this policy. In the event that any supervisor or manager believes that a violation of this policy has occurred or receives a report of a violation, he or she must immediately contact the Director of Human Resources, the General Counsel, the Chief Financial Officer, or the Chief Executive Officer.
If an employee believes that he or she has been retaliated against (including threatened or harassed) in violation of this policy, he or she should immediately report it to the Director of Human Resources, the Director of Internal Audit, the General Counsel, the Chief Financial Officer or the Chief Executive Officer or the Ethics Hotline. Once an employee reports retaliation prohibited by this policy, SEI will promptly investigate the matter. The investigation will be handled as discreetly as reasonably possible, allowing for a fair investigation and any necessary corrective action. Appropriate corrective action will be taken whenever a violation of this policy is determined to have occurred. Depending on the nature of the violation, the offending individual may be subject to disciplinary action up to and including termination. In addition, anyone who interferes with an investigation, or provides information in an investigation that the individual knows to be untrue or inaccurate, will be subject to disciplinary action, up to and including termination of employment. Retaliation against employees who in good faith file a complaint or participate in an investigation is strictly prohibited.
