Whistleblower Policy

Introduction and Purpose

Urban Alchemy (also referred to herein as “organization” or “company”) requires its directors, officers, employees, contractors and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. The purpose of this policy is to encourage and enable employees and volunteers of the Company to report any action or suspected action taken within the Company that is illegal, fraudulent or in violation of any adopted policy of the Company, to a source within the Company before turning to outside parties for resolution. This policy applies to any matter which is related to Urban Alchemy’s business and does not relate to private acts of an individual not connected to the business of Urban Alchemy. This policy is intended to supplement but not replace the organization’s unlawful harassment and discrimination policy, open door policy, and/or any other grievance procedures, and any applicable state and federal laws governing whistleblowing applicable to nonprofit and charitable organizations.

Reporting Violations

All employees and volunteers of Urban Alchemy are encouraged to report any action or suspected action taken within the company that is illegal, fraudulent, or in violation of any adopted policy of Urban Alchemy. Anyone who makes a report under this policy must act in good faith, without malice to Urban Alchemy or any individual in the organization, and have reasonable grounds for believing the information shared in their report. Any report which is made maliciously or any report which the complainant has good reason to believe is false will be viewed as a serious disciplinary offense.

Examples of violations that could be reported under this policy include when a person reasonably believes that the company, or any employee of the company, is:

• Stealing or misappropriating the company’s funds, supplies, or other assets.
• Engaging in fraud or deliberate error in the preparation, evaluation, review, or audit of any financial statement or accounting records.
• Not complying with the company’s internal accounting controls.
• Engaging in quid pro quo transactions with outside parties.
• Violating the company’s conflicts of interest policy.
• Altering or manipulation company documents or computer files in violation of the company’s records management and retention policy and procedures.

Reporting Process

If an individual reasonably believes that the company or someone in the company is engaging in illegal or fraudulent activity, they can report their concern, question, or complaint to any director at the organization.

If an individual does not feel comfortable making the report to an Urban Alchemy director, they can make a report with anyone in management they feel comfortable approaching. They can also make a report to Employee Relations by submitting a report via email to hr@urban-alchemy.us. For individuals who reasonably believe the organization is engaging in illegal activity, financial mismanagement, or misappropriation of charitable assets, they can make a report by emailing legal@urban-alchemy.us or, alternatively, they can make a report through the organization’s private whistleblower hotline by calling 1 (888) 898-6050.

Although the company strongly encourages individuals to identify themselves when making a report, reports made through the hotline’s ticketing system can be made anonymously. Urban Alchemy will explore anonymous allegations to the extent possible, but will weigh the prudence of continuing such investigations against the likelihood of confirming the alleged facts or circumstances from attributable sources.

Investigation Process

All reports will be promptly, thoroughly, and timely investigated. Although Urban Alchemy will attempt to provide as much confidentiality as possible, complete confidentiality cannot be guaranteed, and details of the report will be shared with internal employees who need-to-know such information. Any employees interviewed in an investigation are expected to reasonably cooperate and provide truthful, non-misleading statements. An employee who fails to reasonably cooperate, provides false or misleading information, omits material information, or otherwise intentionally obstructs an investigation will be subject to disciplinary action, up to and including immediate termination.

Employees who participate in an investigation may be required to keep details of any reports, the investigation process, and the outcome of the investigation confidential and secret to protect the integrity of the investigation. Urban Alchemy will impose this requirement only when it is reasonable to do so and only if it is necessary to protect the parties involved or others. In the event Urban Alchemy imposes such a requirement, employees who fail to maintain confidentiality may be subject to disciplinary action.

No Retaliation

No employee who in good-faith makes a report or cooperates in an investigation will be subject to harassment, retaliation, or an adverse employment action for engaging in such activity. If an individual believes that someone who has made a report or who has cooperated in the investigation of a report is being discriminated against, the individual should immediately report this to their supervisor, manager, or to Employee Relations.

Similarly, if an employee believes they are being retaliated against for making a report or participating in an investigation, they can report this to their supervisor, manager, or to Employee Relations. An employee who engages in retaliation in violation of this policy will be subject to disciplinary action.

Accounting and Auditing

The Board of Directors of Urban Alchemy is responsible for addressing all reported concerns or complaints relating to corporate accounting practices, internal controls, or auditing. The Board will be kept apprised of the status of any investigation into valid reports under this policy, and has discretion to engage outside auditors, counsel, or other experts to assist in the investigation and in the analysis of results.

This policy was adopted and approved by the Board of Directors of Urban Alchemy at its Meeting on June 12, 2025. A copy of the Board Resolution is available upon request.