Whistleblower Policy

1. Purpose.

Genesis at the Crossroads requires members of the Board of Directors (“Board”), committee members and other personnel (collectively “Stakeholders”) to observe high standards of business and personal ethics in the conduct of their duties and responsibilities, and all Stakeholders are required to comply with all applicable laws and regulatory requirements.

2. Reporting Responsibility.

Genesis at the Crossroads seeks to have an “Open Door Policy” and encourages all Stakeholders to share their questions, concerns, suggestions, or complaints regarding Genesis at the Crossroads and its operations with someone who can address them properly.  In most cases, a Stakeholder should present his or her concerns to the Founder.  However, if a Stakeholder is not comfortable speaking with the Founder or is not satisfied with the Founder’s response, the Stakeholder is encouraged to speak with anyone on the Board whom the individual is comfortable approaching, or to directly contact Genesis at the Crossroads’ outside legal counsel, whose contact information can be obtained from the Founder.

3. No Retaliation.

No Stakeholder who in good faith reports a violation or alleged violation of a law or regulation requirement shall suffer harassment, retaliation, or, if applicable, adverse employment consequence.  Any Stakeholder who retaliates against someone who has reported a violation or alleged violation in good faith is subject to discipline up to and including termination of his or her affiliation with Genesis at the Crossroads.  This Whistleblower Policy is intended to encourage and enable persons to raise serious concerns within Genesis at the Crossroads prior to seeking resolution outside of Genesis at the Crossroads.

4. Compliance Officer.

Genesis at the Crossroads’ Founder, working with the Board, will act as Genesis at the Crossroads’ Compliance Officer. The Compliance Officer is responsible for investigating and resolving all complaints and allegations concerning violations of applicable laws and regulatory requirements.  A Board member or his or her designee will take on the Compliance Officer role if the complaint involves the Founder.  If the complaint involves both the Founder and Board members, outside legal counsel will carry out the functions of the Compliance Officer.

 5. Accounting and Auditing Matters.

The Board shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The Compliance Officer shall immediately notify the Board of any such complaint and work with the Board until the matter is resolved.

6. Requirement of Good Faith.

Anyone filing a complaint concerning a violation or suspected violation of the law or regulation requirements 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.

7. Confidentiality.

Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

8. Handling of Reported Violations.

The Compliance Officer, or the person responsible for carrying out the Compliance Officer’s role with respect to a reported or suspected violation, will acknowledge receipt of the reported violation or suspected violation by writing a letter (or e-mail) to the complainant within five business days.  All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.