Whistleblower Policy

RESPONSIBILITIES OF AUDIT COMMITTEE

The Audit Committee of the board of directors has established the following procedures to receive, retain, investigate and act on complaints and concerns of directors, coaches, swimmers, parents/guardians and others regarding: a. violations of the Seals Code of Conduct, b. retaliation against directors, coaches, swimmers, parents/guardians who make reports. At the discretion of the Audit Committee, the Audit Committee’s responsibilities created by these procedures may be delegated to a subcommittee of the Audit Committee.

PROCEDURES FOR RECEIVING AND INVESTIGATING REPORTS

1. Reports may be made to the Audit Committee by telephone, email or in writing to the attention of the Audit Committee. Any report received by a Seals board of director or coach should be forwarded immediately to the Audit Committee.

2. Promptly upon receipt, the Audit Committee will evaluate whether a complaint constitutes a report. If the Audit Committee deems the complaint a report, they will create a Complaint Summary, summarizing in reasonable detail the nature of the report (including any specific allegations made and the persons involved), the date of receipt of the report, the current status of any investigation into the report, and any final resolution of the report. The Audit Committee will report any recent developments of items listed in the summary to the Board of Directors at, or in advance of, each regularly scheduled meeting, or more frequently, if warranted. All members of the Audit Committee will be provided full access to the docket and all information related to any reports received.

3. In the event a report involves or implicates a member of the Audit Committee, that individual will promptly remove themselves from the investigation. The Audit Committee may thereafter promptly appoint impartial Board Members to investigate the report.

4. If the Audit Committee determines that a complaint is a report, they will promptly investigate the report and communicate the results in reasonable detail to the Board of Directors, including a description of the report, the steps taken in the investigation, any factual findings and the recommendations of the corrective action, if applicable. All investigations will be conducted in a confidential manner, so that information will be disclosed only as needed to facilitate review of the investigation.

PROTECTION OF WHISTLEBLOWERS

Consistent with the policies of Seals Swimming, the Audit Committee, Board of directors or coaches will not retaliate or attempt to retaliate, and will not tolerate any retaliation or attempted retaliation by any other person or group, directly or indirectly, against anyone who, in good faith, makes a report or provides assistance to the Audit Committee or Board of Directors or any other person or group investigating or otherwise helping to resolve a report.

CONFIDENTAIL AND ANONYMOUS REPORTS

1. All reports received using the procedures outlined above will be treated confidentially or anonymously, as applicable, to the extent reasonable and practicable under the circumstances.

RECORDS

1. The Audit Committee will retain on a strictly confidential basis for a period of five years all records relating to any report and to the investigation its resolution. All such records are confidential to the Board of Directors and are considered privileged and confidential. PUBLICATION OF PROCEDURES 1. The Board of Directors will communicate these procedures to all members and post them for viewing. 10/9/13