The Audit Committee has established the following procedures for the managers, employees, former employees and vendors of "Your Company" to confidentially submit concerns regarding questionable accounting or auditing practices. TeleSentry LLC has been contracted by "Your Company" to manage and staff a toll free number that will specifically be used to process employee concerns with the companies Code of Conduct. TeleSentry will employ various technologies and industry accepted practices to ensure the anonymity of each caller. TeleSentry LLC is not nor will it provide any services to "Your Company" other than those services specifically related to managing these confidential reporting communication channels.

1. PROCEDURES
   1. "Your Company" with the assistance of TeleSentry LLC will maintain an anonymous 24/7 toll-free telephone number to serve as 'Your Company's" Hotline.
   2. The Hotline number is (___ ___ ____).
   3. Your Company's Hotline will be staffed 24/7.
      1. Your Compliance Officer or designee will review TeleSentry's call in-take process and add any specific questions.
      2. Company designed personnel will receive reports via email.
   4. TeleSentry will makes its best efforts to preserve the anonymity of each caller.
   1. Each caller will be advised that hey have reached an anonymous reporting hotline for Code of Conduct concerns.
   2. All calls will be assigned a unique personal identification number (protected password). The caller will be given this number and advised to call back if they have questions, additional information, or if they are inquiring about the status of an investigation.
   3. Each caller will be assured that 'Your Company" will not tolerate any retaliation against the caller.
   4. All information given by the caller will be reported to the company. If the caller is fearful that an investigation of the information provided would reveal his/her identity that information will be included in the report.
2. DOCUMENTATION
1. Hotline calls will be documented in a hotline log and the hotline report. The report and log will contain information on the allegation, status of review and resolution.
2. A TeleSentry call summary form will be completed for each call.
   1. Each form will be filled out completely and as accurately as possible.
   2. Each form will contain a unique identification number assigned to each call.
   3. The date and time will appear on each form.
   4. Name, location and phone number of caller (if caller does not wish to remain anonymous.)
   5. Nature of call.
   6. Description/summary of callers concern in third person.
   7. Are follow-up actions required? If yes, what?
   8. Each completed form will be reviewed by a TeleSentry supervisor for clarity and thoroughness and forwarded to the designated recipient at "Your Company".
   9. TeleSentry's Hotline staff will be trained in new compliance developments.
   10. A caller may call to retrieve replies or add additional information.
       1. The caller will be requested to provide their personal identification code assigned during the first call.
       2. The Company will provided an email response tool to respond to the caller and/or ask questions.