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Policy on Non-Retaliation <br /> PURPOSE: <br /> NSMT has adopted this Non-Retaliation Policy to reinforce its commitment to prevent and protect employees <br /> from retaliation for reporting, in good faith, suspected wrongdoings and/or for assisting in an investigation. <br /> POLICY AND PROCEDURE: I. <br /> INTRODUCTION <br /> As outlined in NSMT Code of Conduct, it is the policy of NSMT to foster an environment of open <br /> communication so that all employees understand their obligations to report compliance concerns and <br /> understand that the Company will not tolerate retaliation against those who do so. In addition, reported <br /> concerns will be maintained confidentially, to the extent it is possible to do so. <br /> "Getting even"behavior is not tolerated and all reported allegations of retaliation are fully investigated <br /> by the Compliance Officer with the assistance of other departments, as appropriate. All Management is <br /> responsible for enforcing this policy. Individuals who violate this policy will be subject to the <br /> appropriate and applicable disciplinary process, up to and including termination or dismissal. <br /> II. INVESTIGATION OF RETALIATION CLAIMS, <br /> Employees who believe they have been retaliated against for reporting, in good faith, suspected <br /> wrongdoings and/or assisting with an investigation, should report the issue by submitting a report through <br /> the anonymous reporting portal found in E-Pro or by calling the Compliance Officer directly at 919-210- <br /> 1172. It is important to file the report of retaliation as soon as possible after the occurrence as a delay can <br /> impact the effectiveness of the investigation. <br /> After a report of retaliation has been received, the NSMT Compliance Officer will begin an investigation. <br /> The investigation involves interviewing all appropriate individuals and reviewing relevant documentation <br /> to determine the validity of the report of retaliation. Corrective action may be warranted pending the <br /> outcome of the investigation. <br /> POLICY REVIEW <br /> The NSMT Compliance Officer will review and update this Policy and all Compliance policies when <br /> necessary in the normal course of its review of the NSMT Compliance Program. <br /> 11 <br />