Whistle Blowing

The National Conference of CPA Practitioners (hereinafter ‘ncCPAp’) has established a
Code of Conduct addressing ethics and conflicts of interest.  This Code requires directors,
officers, committee chairs and committee members, and employees (hereinafter
‘associates’) to observe high standards of business and personal ethics in the conduct of
their duties and responsibilities.

All associates must practice honesty and integrity in fulfilling their responsibilities.
They also must comply with all applicable laws and regulations.

Reporting Responsibility

It is the responsibility of all associates to comply with the Code and to report violations
or suspected violations in accordance with this Whistleblower Policy.

No Retaliation

No associate who in good faith reports a violation of the Code shall suffer harassment,
retaliation or other adverse consequence. An employee who retaliates against someone
who has reported a violation in good faith is subject to discipline up to and including
termination of employment.

This Whistleblower Policy is intended to encourage and enable associates to raise serious
concerns within the Organization prior to seeking resolution outside the Organization.

Reporting Violations

The Code addresses the Organization’s open door policy and suggests that associates
share their questions, concerns, suggestions or complaints with someone who can address
them properly. In most cases, a member of the Ethics Committee is in the best position
to address an area of concern. However, if an associate is not comfortable speaking with
a member of the Ethics Committee, or is not satisfied with the member of the Ethics
Committee’s response, he or she is encouraged to speak with the President.

For suspected fraud, he or she should contact the Ethics Committee directly.

Ethics Committee

ncCPAp’s Ethics Committee is responsible for investigating and resolving all reported
complaints and allegations concerning violations of the Code and, at its discretion, shall
advise the President. The Ethics Committee has direct access to the Board of Directors
and is required to report to the Board at least annually on compliance activity.

Accounting and Auditing Matters

The Finance Committee of the Board of Directors shall address all reported concerns or
complaints regarding corporate accounting practices, internal controls or auditing. The
Ethics Committee chair shall immediately notify the Finance Committee of any such
complaint and work with the Finance Committee until the matter is resolved.

Acting in Good Faith

Anyone filing a complaint concerning a violation or suspected violation of the Code must
be acting in good faith. He or she must have reasonable grounds for believing the
information disclosed indicates a violation of the Code. Any allegations that prove not to
be substantiated and which prove to have been made maliciously or knowingly to be false
will be viewed as a basis for review by the Ethics Committee.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the
complainant or may be submitted anonymously. Reports of violations or suspected
violations will be kept confidential to the extent possible, consistent with the need to
conduct an adequate investigation.

Handling of Reported Violations

The Ethics Committee chair will notify the sender, acknowledging receipt of the reported
violation or suspected violation within five business days when practical. All reports will
be promptly investigated and appropriate corrective action will be taken if warranted by
the investigation.

Ethics Committee Chairperson
National Conference of CPA Practitioners