OPERATING PRACTICES, STANDARDS, AND POLICIES Complaint Procedures BB&N will not tolerate harassment or victimization of the Infractions of all discrimination and harassment and other BB&N complainant and will make every e昀昀ort to protect the complainant’s policies should be reported immediately to the Director of Human identity. However, it is important to note that malicious allegations Resources and/or the Chief Operating/Financial O昀케cer. BB&N takes may result in disciplinary action. BB&N also encourages employees to complaints seriously and will respond promptly. put their names to allegations to allow the school to properly follow- up and complete an investigation into the complaint. Concerns In the event of a complaint against a BB&N employee requiring an expressed anonymously will be investigated, taking into account the investigation, the employee will be noti昀椀ed of the steps involved in seriousness of the issue raised, the credibility of the concern, and the the investigatory process, which may include paid administrative likelihood of con昀椀rming the allegation from attributable sources. leave during the pendency of the investigation, and whether third parties will be involved in the investigation. Employees on paid BB&N encourages employees to report ethical concerns or administrative leave generally do not report to work or perform allegations internally. The school has also implemented a program any work-related tasks. Con昀椀dentiality will be maintained to the through NAVEX to provide an anonymous and con昀椀dential method extent that it is practical under the circumstances. When BB&N has of reporting misconduct. To submit a report, contact NAVEX by completed its investigation, to the extent appropriate, the person calling 844-516-3777 or going online at NAVEX Reporting. 昀椀ling the complaint and the employee subject to the complaint will be informed of the results of the investigation. Whistleblower Policy BB&N is committed to the highest possible standards of ethical, moral, and legal business conduct. In line with this commitment and the school’s commitment to open communication, the Whistleblower Policy applies to all BB&N employees, including part- time, temporary, and contract employees, and aims to provide an avenue for employees to raise concerns and reassurance that they will be protected from reprisals or victimization for whistleblowing in good faith. The Whistleblower Policy is intended to cover serious concerns that could have an impact on the school, such as actions that: • May lead to incorrect 昀椀nancial reporting; • Are unlawful; • Are not in line with school policy, including the community standards; • Otherwise amount to serious improper conduct. - 29 -