PHILOSOPHY

Lucy’s Warriors Foundation 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 organization, 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 Lucy’s Warriors Foundation 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 Lucy’s Warriors Foundation’s code of ethics or suspected violations of law or regulations that govern its operations.

NO RETALIATION

It is contrary to the values of Lucy’s Warriors Foundation 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 the organization. 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

Lucy’s Warriors Foundation 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 President and Co-Founder, or a board member. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to Lucy’s Warriors Foundation’s President and Co-Founder, who has the responsibility to investigate all reported complaints about unethical or illegal conduct and ensure they are investigated and resolved. President and Co-Founder will report at least annually to the Treasurer on compliance activity relating to accounting or alleged financial improprieties.

ACCOUNTING AND AUDITING MATTERS

The President and Co-Founder shall immediately notify the Treasurer of any concerns or complaints 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

Lucy’s Warriors Foundation, President and Co-Founder 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.

President and Co-Founder:

Janey Sprouse-Cadenas janeymcadenas@gmail.com 719-722-9893

Approved by the Board of Directors on July 31, 2024.