A. Each of the programs sponsored or promoted by itrek, inc. (“itrek”) (including, without limitation, Graduate, REALITY, Launchpad, and Network) aim at all times to conduct its business with the highest standards of integrity and honesty and in compliance with its Code of Conduct and all applicable laws. itrek expects all affiliates, programs, partners, officers, employees, agents, members, and any other person acting with or on their behalf to maintain the same standards and uphold the Code of Conduct in everything they do.  Therefore, you are encouraged to use this Code of Conduct Violation Report (the “Report”) if you have concerns about any possible violations of the Code of Conduct by any such person.

 

B. Reports may be made anonymously. In responding to any report, itrek will investigate as appropriate any individual named in the Report, the seriousness of the issue raised, the credibility of the information or allegations in the Report, and the prospect of an effective investigation.

C. Investigations will be conducted as quickly as possible, taking into account the nature and complexity of the Report and the issues raised. The content of the investigation, including the underlying report, will be kept confidential to the extent reasonably possible and subject to any disclosures required by law or, in itrek’s discretion, to governmental agencies or regulators or to the subjects of any investigation.

D. If you wish to make the Report anonymously, please ensure you have taken all steps necessary to do so. For instance, ensure that you have not included your name, address or other identifying information on any letter or email included.

E. The Report should be factual rather than speculative or conclusory and should contain as much specific information as possible to allow for proper assessment. In addition, the Report should contain sufficient corroborating information to support the commencement of an investigation. Claims must be made candidly and in good faith.

F. itrek will not discharge, demote, discipline, suspend, threaten, harass, directly or indirectly, or in any other manner retaliate against any person for submitting a good faith Report.  Any partner, officer, employee, agent, member, and any other person acting with or on behalf of itrek who violates the previous sentence by retaliating against or harassing a person who has reported in good faith will face disciplinary action.