Pinwheel Terms & Policies

Contents

Website Privacy PolicyEnd User Privacy PolicyTerms of ServiceResponsible Disclosure PolicyDeveloper PolicyWhistleblower Policy

Whistleblower Protection Policy

Last Updated: June 23, 2020.

Underdog Technologies, Inc. dba Pinwheel (“Pinwheel”) requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the Pinwheel, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that Pinwheel can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees and volunteers to report concerns about violations of Pinwheel’s code of ethics or suspected violations of law or regulations that govern Pinwheel’s operations.

No Retaliation

It is contrary to the values of Pinwheel for anyone to retaliate against any board member, officer, employee or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of Pinwheel. 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

Reporting Procedure

Pinwheel has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with the Board of Directors. All correspondences should go to ethics@getpinwheel.com. The Chief Compliance Officer is the only one who will receive access to that inbox. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the Pinwheel’s Chief Compliance Officer, who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or the Board of Directors or the organization’s Chief Compliance Officer.

Accounting and Auditing Matters

Pinwheel’s Chief Compliance Officer shall immediately notify the Board of Directors of any concerns or complaint regarding corporate accounting practices, internal controls or auditing and work with the committee until the matter is resolved.

Acting in Good Faith

Anyone filing 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.

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.

Handling of Reported Violations

Pinwheel’s Chief Compliance Officer 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. Chief Compliance Officer: Curtis Lee, Member of the Board of Directors.