Whistleblowing and Public Interest Disclosure Policy

1.Purpose and scope

The Society is committed to the highest standards of openness, integrity and accountability. This policy enables staff, elected officers, trustees, volunteers, chapter leaders, contractors and members to raise genuine concerns about suspected wrongdoing at an early stage and in the right way, without fear of reprisal.

It applies across all ACS operations, including the Austin headquarters and all chartered chapters and committees, and supplements but does not replace the Code of Conduct and standard grievance procedures for personal employment disputes.

2.Protected disclosures

1. 2.1A violation of federal, state or local law or regulation.
2. 2.2Financial fraud, misappropriation of funds or accounting irregularities.
3. 2.3A danger to the health or safety of any individual, or damage to the environment.
4. 2.4Improper conduct in the certification, examination or accreditation processes that compromises their integrity.
5. 2.5Conflicts of interest not properly disclosed or managed.
6. 2.6Discrimination, harassment or retaliation inconsistent with ACS policy or law, or deliberate concealment of any of the above.
7. 2.7Disclosures made in good faith are protected even if the concern later proves mistaken, provided the discloser reasonably believed the information to be substantially true at the time. Knowingly false reports made maliciously are not protected.

3.How to raise a concern

1. 3.1Directly with a manager or supervisor, for routine or lower-risk concerns.
2. 3.2With the Director of Professional Standards, acting as Ethics and Compliance Officer, for concerns involving management, finance or certification integrity.
3. 3.3With the Chair of the Audit, Risk & Finance Committee, for concerns involving senior executives or trustees.
4. 3.4Through the confidential reporting line, for any concern the discloser wishes to raise anonymously or without direct contact.

4.Confidential reporting line

ACS maintains an independently operated confidential reporting line, available by secure web portal and telephone twenty-four hours a day, in English and Spanish. Reports may be made anonymously.

All reports are logged by the independent provider and forwarded to the Ethics and Compliance Officer or, where the concern implicates that office, directly to the Chair of the Audit, Risk & Finance Committee, with the discloser's identity withheld unless voluntarily disclosed.

5.Investigation

All disclosures are acknowledged within five business days. An initial assessment determines whether the matter falls within this policy and the appropriate investigation route.

Concerns are investigated proportionately and objectively by an appropriately independent individual or panel, which may include external counsel or forensic accountants. Investigations are confidential, with information shared only on a need-to-know basis.

The discloser is entitled to an outcome summary consistent with confidentiality and privacy obligations, normally within sixty calendar days, or an explanation of any delay. Substantiated findings are reported to the Audit, Risk & Finance Committee and, where appropriate, the full Board.

6.Protection from retaliation

ACS strictly prohibits retaliation of any kind against any individual who makes a good-faith protected disclosure, including dismissal, demotion, harassment, exclusion from volunteer roles or adverse changes to certification or membership standing.

Any person who retaliates is subject to disciplinary action up to and including termination of employment, removal from office or revocation of membership and credentials. Reports of retaliation are treated with the same urgency as the original disclosure.

7.External escalation and review

While ACS encourages concerns to be raised internally first so they can be addressed promptly, nothing in this policy prevents any individual from reporting directly to an appropriate external authority, including the Internal Revenue Service, the Securities and Exchange Commission, the Occupational Safety and Health Administration, state attorneys general or other relevant regulators.

Individuals retain all rights and protections afforded under applicable federal and state whistleblower statutes, including the Sarbanes-Oxley Act, the Dodd-Frank Act and Texas state law, regardless of whether they have first used internal channels.

This policy is reviewed by the Audit, Risk & Finance Committee at least every three years, or sooner following any significant incident or change in applicable law, with amendments subject to Board approval.