POLICY AND PROCEDURES Whistleblower Protection Policy

Under Michigan Law, Kadima will comply with Michigan’s Whistleblower Protection Act (469 P.A. 1980). It is the intent of Kadima to adhere to all laws and regulations that apply to the organization and the underlying purpose of this policy is to support the organizations goal of legal compliance.

Reporting Responsibility

If any employee reasonably believes that some policy, practice, or activity of Kadima is in violation of law, a policy or rule, a written complaint must be filed by the employee with the HR Director or Executive Director. This policy is intended to encourage and enable employees to raise serious concerns internally so that Kadima can address and correct inappropriate conduct and actions.

No Retaliation

Kadima will not retaliate against an employee who in good faith, has made a protest or raised a complaint against some practice of Kadima, or of another individual or entity with whom Kadima has a business relationship, on the basis of a reasonable belief that the practice is in violation of law, or a clear mandate of public policy.

Acting in Good Faith

If any employee should file a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. 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.

Handling of Reported Violations

Kadima’s HR Director or Executive Director will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

Confidentiality

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

Whistleblower Protection Policy May 2016