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Compliance Reporting Hotline Compliance and Ethics Hotline Policy


SCOPE:
This policy applies to all YTI Career Institute employees, students and associates.

PURPOSE
YTI Career Institute is committed to the highest possible standards of ethical, moral and legal business conduct. In conjunction with this commitment and YTI's commitment to transparency, this policy aims to provide an avenue for employees and constituents to raise concerns regarding the administration of Federal Student Aid Programs; possible violations of institutional or programmatic accreditation standards; violations of state regulatory requirements; unethical conduct; illegal conduct; and fraud choose to report anonymously. However, if an employee feels that their anonymity is not required then they should follow our existing grievance procedure.

POLICY:
The compliance hotline policy is intended to cover serious concerns that could have a large impact on YTI, such as actions that:

  • May lead to incorrect financial reporting;
  • Are unlawful;
  • Are not in line with company policy, including the Code of Business Conduct; or
  • Otherwise amount to serious improper conduct.

Regular business matters that that do not require anonymity should be directed to the employee's supervisor and are not addressed by this policy.

SAFEGUARDS:

Harassment or Victimization
Harassment or victimization of individuals submitting hotline reports will not be tolerated.

Confidentiality
Every effort will be made to protect the reporter's identity by our hotline vendor. Please note that the information provided in a hotline report may be the basis of an internal and/or external investigation by our company into the issue being reported. It is possible that as a result of the information provided in a report the reporter's identity may become known to us during the course of our investigation.

Anonymous Allegations
The policy allows employees to remain anonymous at their option. Concerns expressed anonymously will be investigated, but consideration will be given to:

  • The seriousness of the issue raised;
  • The credibility of the concern; and
  • The likelihood of confirming the allegation from attributable sources.

Malicious Allegations
Malicious allegations may result in disciplinary action.

PROCEDURE:

Reporting
The compliance hotline procedure is intended to be used for serious and sensitive issues. Serious concerns relating to financial reporting, unethical or illegal conduct, should be reported in either of the following ways:

  • Toll-free number: (800) 401-8004
  • Website: www.lighthouse-services.com/yti
  • E-mail: reports@lighthouse-services.com (must include company name with report)
  • Fax alternative for written documents: 215-689-3885 (must include company name with report)

Reporters to the hotline will have the ability to remain anonymous if they choose. Please note that the information provided by you may be the basis of an internal and/or external investigation into the issue you are reporting and your anonymity will be protected to the extent possible by law. However, your identity may become known during the course of the investigation because of the information you have provided. Reports are submitted by Lighthouse to YTI Corporation or its designee, and may or may not be investigated at the sole discretion of our company.

Employment-related concerns should continue to be reported through your normal channels such as your supervisor, Campus President, or the Human Resources Department. See the Staff Policy Manual for the Grievance Policy (308).

Timing
The earlier a concern is expressed, the easier it is for us to take action.

Evidence
Although you are not expected to prove the truth of an allegation, the employee submitting a report needs to demonstrate in their hotline report that there are sufficient grounds for concern.

HOW THE REPORT WILL BE HANDLED:
The action taken will depend on the nature of the concern. The Audit Committee of YTI's Board of Directors will receive a copy of each report and follow-up reports on actions taken by the company.

Initial Inquiries
Initial inquiries will be made to determine whether an investigation is appropriate, and the form that it should take. Some concerns may be resolved by agreed upon action without the need for an investigation.

Feedback to Reporter
Whether reported directly to YTI Home Office personnel or through the hotline, the individual submitting a report will be given the opportunity to receive follow-up on their concern:

  • Acknowledging that the concern was received;
  • Indicating how the matter will be dealt with;
  • Giving an estimate of the time that it will take for a final response;
  • Telling them whether initial inquiries have been made;
  • Telling them whether further investigations will follow, and if not, why not.

Further Information
The amount of contact between the individual submitting a report and the body investigating the concern will depend on the nature of the issue, the clarity of information provided, and whether the employee remains accessible for follow-up. Further information may be sought from the reporter.

Outcome of an Investigation
At the discretion of the company and subject to legal and other constraints the reporter may be entitled to receive information about the outcome of an investigation.

YTI reserves the right to modify or amend this policy at any time as it may deem necessary.

 


 
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