Wood Industry Assocation Whistleblower Policy
As Approved February 7, 2024

Procedures for the Submission of Complaints or Concerns Regarding Financial Statement or other Disclosures, Accounting, Internal Accounting

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The Wood Industry Association (“the Association”) has a responsibility for the stewardship of its resources. In addition to complying with the law, it is the policy of the Association to promote ethical practices and ethical treatment of its members and staff. Instances of known or suspected misuse of the Association’s resources or other improper activities should be reported and appropriately investigated. Members, directors and staff have a responsibility to each other and to the organization to maintain an environment in which (i) problems are reported and addressed immediately, and (ii) those who make such reports are protected from retaliation.

The Association endorses and utilizes internal controls and operating procedures intended to prevent and detect improper activities.

The objective of the Association’s Whistleblower Policy is to establish policies and procedures for:

1. The submission of concerns regarding questionable financial statement or other disclosures, accounting, internal accounting or disclosure controls or auditing matters by staff, directors, officers and other stakeholders of the organization on a confidential and anonymous basis.
2. The receipt, retention, and treatment of complaints received by the Association regarding accounting, internal controls or auditing matters.
3. The protection of all who report concerns from retaliatory actions.

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Procedure for Raising a Concern

1. The Association’s Board of Directors and staff shall promptly forward to the Executive Committee any complaints received regarding financial statement disclosures, accounting, internal accounting or disclosure controls or auditing matters, or disclosure violations. Any complaint will first be evaluated to determine whether it falls within the scope of this Policy. If it does not, it will be forwarded to the Association’s General Counsel to address in a manner in which he or she deems appropriate.

2. Any staff person or member of the Association may submit, on either a confidential, anonymous basis or a non-confidential, non-anonymous basis, any good faith concerns regarding financial statement or other disclosure, accounting, internal accounting or disclosure controls, or auditing matters to the Association’s General Counsel:

Pannos Law LLC
1485 Chain Bridge Road, Suite 204
McLean, VA 22101
(847) 954-7178
michael.deese@pannos-law.com

3. Following the receipt of a complaint or concern within the scope of this Policy, the Executive Committee will investigate each matter reported and recommend corrective or disciplinary actions to the Board of Directors. The status of all pending complaints will be reviewed at each regularly scheduled Executive Committee meeting.

4. The Executive Committee may enlist committee members, staff, and/or outside legal, accounting or other advisors, as appropriate, to conduct any investigation of complaints under this Policy. In conducting any investigation, and to the extent possible consistent with the need to conduct an adequate review of any complaint or concern, the Executive Committee shall use reasonable efforts to attempt to protect the confidentiality and anonymity of the complainant.

5. The Association does not permit retaliation of any kind against staff or members for complaints submitted hereunder that are made in good faith. Should the identity of any person making a complaint or reporting a concern hereunder become known, the Executive Committee shall monitor any disciplinary action against such person. Additionally, no staff person or member shall be adversely affected because the staff person or member refuses to carry out a directive which, in fact, constitutes corporate fraud or is a violation of state or federal law.

6. The Executive Committee shall retain as a part of its records, for a period of no less than seven (7) years, all such complaints or concerns, together with the proceedings of the Committee with respect thereto. All such records will be treated as confidential information.