Facts Check and Scam Report

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At IntellCorp, we are committed to the highest levels of ethics and integrity in the way that we do business. We understand that this is crucial to our continued success and reputation. Our Shared Values, Principles of Business Conduct, and policies guide our everyday conduct. We have a professional responsibility to speak up and report unethical behavior.

We expect everyone who works for IntellCorp to comply with our Principles of Business Conduct, our policies and procedures, professional standards, laws and regulations.

You also have a responsibility to speak up using one of the many channels available when you suspect something does not look or feel right.
We encourage you to consider talking to IntellCorp. We would rather hear your concerns directly so that we can resolve them directly.

If you make a Report pursuant to this Policy, we have a responsibility to protect you, including not disclosing your identity (unless required or permitted by law) and making sure you are not subject to Detrimental Conduct.

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What is IntellCorp a Reportable Conduct?

Reportable Conduct is anything that you have reasonable grounds to suspect, in relation to IntellCorp :
· Misconduct of an associate or partner or someone who claims to work for or with IntellCorp, as an improper state of affairs or circumstances;

· Conduct that constitutes a contravention of laws; or · conduct that represents a danger to yourself, the public or the financial system.

 

Examples of Reportable Conduct include but are not limited to:
Illegal conduct, such as theft, violence or threatened violence, and criminal damage against property;
· Fraud, money laundering or misappropriation of funds;
· Offering or accepting a bribe;
· Financial irregularities;
Failure to comply with, or breach of, legal or regulatory requirements; and
· Engaging in or threatening to engage in Detrimental Conduct against yourself or someone you know.

 

What should I include in the report?

Please provide as much detailed information as possible so that your report can be investigated. Some useful details include:
· Date, time and location;
· Names of person (s) involved, roles and all available details;
· Your relationship with the person (s) involved;
· The general nature of your concern;
· How you became aware of the issue;
· Possible witnesses; and
· Other information that you have to support your report.

Should I make a Report anonymously?

You can choose to make your disclosure anonymously and if so, you will still be protected. However, requiring complete anonymity may practically make it more difficult for us to investigate the issue or take the action we would like to take. By letting us know who you are, we can contact you directly to discuss your concerns which will help us investigate the complaint more quickly and efficiently.

Identity Protection

Where you make a disclosure, your identity (or any information which could identify you) will only be shared where:
· You provide consent; or
· IntellCorp is permitted, or otherwise required, by law.

However, you should be aware that in certain circumstances IntellCorp may not need your consent to share your disclosure if:
· The information does not include your identity;
· We have taken all reasonable steps to reduce the risk that you will be identified from the information;
and
· It is reasonably necessary for investigating the issues raised in the Report.

 

Who will assess or investigate my matter?

All Reports will be considered by IntellCorp, who will appoint a top associate to investigate the Report.

How will my Report be reviewed by IntellCorp?

All Reports will be taken seriously by IntellCorp. They will all be carefully assessed to determine whether an investigation is required. The outcomes of the investigation are reported to you. IntellCorp will, depending on the outcome, determine appropriate actions to respond to the matter.

What is the investigation process?

While the particular circumstances of each Report may require different investigation steps, all investigations will:
· Follow a fair process;
· Be conducted as quickly and efficiently as the circumstances permit;
· Determine whether there is enough evidence to substantiate the matters reported; and
· Be independent of the person (s) concerned with the allegations.
We will provide you with feedback, as appropriate on the progress and expected time frames of the investigation.

 

Fair treatment of the individuals mentioned in the Report

The investigation process outlined in this Policy is also designed to allow fair treatment of any individuals mentioned in the disclosure; including:
· Disclosures will be handled confidentially;
· Matters reported will be assessed and may be subject to an investigation;
· There will be a presumption of innocence until the outcome of the investigation is determined ; and
· The purpose of the investigation is to determine whether there is enough evidence to substantiate the matters reported.

What happens after an investigation?

 

IntellCorp will notify you once an investigation has been completed but please be aware that IntellCorp may be unable to disclose particular details or the outcome of the investigation.

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False or misleading disclosures

When making a disclosure, you will be expected to have reasonable grounds to suspect the information you are disclosing is true, but you will not be subject to a penalty if the information turns out to be incorrect.
However, you must not make a report that you know is not true or is misleading. This may be a breach of our Principles of Business Conduct and will be considered a serious matter that may result in legal consequences, if you make a knowingly false report.

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