Chapter 2: Foundational Materials and Program Infrastructure

Model Anti-Retaliation Policy


Effective Date


Global Compliance

[Effective Date]


Scope: This policy applies to [Company], including its subsidiaries (collectively, “[Company Name]” or the “Company”), and the directors, officers, and employees of such entities, as well as all those acting for or on behalf of the Company (collectively, “Covered Individuals”).

Purpose: To protect all employees of the Company from any form of retaliation for speaking up about a potential compliance issue. This policy reinforces the Company’s commitment to ensuring a speak-up culture where all employees feel safe raising issues and concerns without fear of being retaliated against for doing so.

Any employee who, in good faith, reports a suspected violation, assists in the investigation of a potential issue, or requests information or clarification about the proper interpretation or application of any law, our Code of Conduct, or any Company policy or procedure should be able to do so freely and without worrying they will be retaliated against as a result.

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