1/9/2019
Whistleblower Policy
Best Rate Capital Inc. DBA BRC’s Code of Conduct (hereinafter referred to as the Code) requires employers, employees, and 3rd party vendors interacting with BRC to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of the organization must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations.
This policy is intended to help past and present employees, customers, or others report suspected or actual occurrence(s) of illegal, fraudulent, unfair, unsafe, dangerous, unethical or inappropriate events (behaviors or practices) without retribution. This includes but is not limited to conduct that may effect the safety, soundness, or reputation of the institution.
Nathan Baram is adequately trained on handling whistleblower complaints and is competent in managing investigations into such.
1. The Whistleblower should promptly report the suspected or actual event to Nathan Baram via e-mail at broker@bestratecapital.com or call him at 631-360-0003.
2. The Whistleblower can report the event with his/her identity or anonymously.
3. The Whistle blower shall receive no retaliation or retribution for a report that was provided in good faith – that was not done primarily with malice to damage another or the Whistleblower who makes a report that is not done in good faith is subject to discipline, including termination of relationship, or other legal means to protect the reputation of the organization and members of its Board and staff.
4. Anyone who retaliates against the Whistleblower (who reported an event in good faith) will be subject to discipline, including termination.
5. Crimes against person or property, such as assault, rape, burglary, etc., should immediately be reported to local law enforcement personnel.
6. Supervisors, managers and/or Board members who receive the reports must promptly act to investigate and/or resolve the issue and keep documentation of such.
7. The Whistleblower shall receive a report within five business days of the initial report, regarding the investigation, disposition or resolution of the issue.
8. If the investigation of a report, that was done in good faith and investigated by internal personnel, is not to the Whistleblower’s satisfaction, then he/she has the right to report the event to the appropriate legal or investigative agency.
9. The identity of the Whistleblower, if known, shall remain confidential to those persons directly involved in applying this policy, unless the issue requires investigation by law enforcement, in which case members of the organization are subject to subpoena.
10. This policy will be reviewed with all employees and independent contractors at least annually.
11. This policy is posted on the website at www.BestRateCapital.com
12. Nathan Baram, President of BRC will ensure investigation is done properly and all details documented until satisfactory outcome/resolution is achieved.