604-7 Whistleblower

Title:	Whistleblower Policy
Owner:	Human Resources
Last Update/Revised:	06/28/2021

Policy: A whistleblower is defined as an employee of AGI/AU/USU who reports an activity that he/she considers to be illegal or dishonest. If employees have information regarding possible violations of state or federal statutes, rules, or regulations, or violations of fiduciary responsibility by the Company, Aspen University encourages employees to report it immediately to their manager or Human Resources.

When employees notify a supervisor, manager, or an appropriate government or law enforcement agency that they have reason to believe their employer is violating a state or federal statute, or violating or not complying with a state or federal rule or regulation, those employees are protected from retaliation. As such, the Company has a strict policy that prohibits retaliation against employees who make such reports while employed in any form of employment. The Company also does not permit retaliation against employees who refuse to participate in an activity that would result in a violation of a state or federal statute, or a violation or noncompliance with a state or federal rule or regulation.

If an employee wishes to report any such matters anonymously, employees may call the appropriate Whistleblower Hotline. Reports from the Whistleblower Hotline will be sent directly to Aspen University's outside legal counsel and Aspen University's Executive Committee Chair, who is not an employee of AGI, AU, or USU:

Whistleblower Hotline for AU & AGI Employees:
U.S. Callers: (888) 883-1499
International Callers: (203) 227-1908
Via E-mail at reports@lighthouse-services.com

Alternatively, if you are an employee in California, you may contact the California State Attorney General's Whistleblower Hotline at (800) 952-5225. The Attorney General will refer your call to the appropriate government authority for review and possible investigation.