The Organization

The Open Application Group’s (Organization) Code of Conduct requires directors, principal officers, staff or member of a committee with governing board delegated powers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As representatives of the Organization, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility

It is the responsibility of all directors, principal officers, staff or member of a committee with governing board delegated powers to comply with the Code and to report violations or suspected violations in accordance with this Whistleblower Policy.

No Retaliation

No directors, principal officers, staff or member of a committee with governing board delegated powers who in good faith reports a violation of the Code shall suffer harassment, retaliation or adverse consequence. A staff or member who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment or membership. This Whistleblower Policy is intended to encourage and enable staff, AgGateway members and others 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 staff and members share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, a director, principal officer, staff or member of a committee with governing board delegated powers is in the best position to address an area of concern. Directors, principal officers, staff or member of a committee with governing board delegated powers are required to report suspected violations of the Code of Conduct to the Organization's Board Chairman who has specific and exclusive responsibility to investigate all reported violations. For suspected fraud, or when you are not satisfied or uncomfortable with following the Organization's open-door policy, individuals should contact the Organization's Board Chairman directly.

Compliance Officer / Board Chairman

The Organization's Board Chairman is the Compliance Officer and is responsible for investigating and resolving all reported complaints and allegations concerning violations of the Code and, at his discretion, shall advise the Executive Committee.

Accounting and Auditing Matters

The Executive Committee of the board of directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. Acting in Good Faith

Anyone filing a complaint concerning a violation or suspected violation of the Code must be acting in good faith and 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 serious disciplinary offense.

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 Compliance Officer will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days. All reports will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation.