APPENDIX FIVE B

Whistleblower Program

REPORTS REGARDING ACCOUNTING MATTERS

ABC Company is committed to compliance with applicable laws, rules and regulations, accounting standards, and internal accounting controls. Every employee is expected to report any complaints or concerns regarding accounting standards, internal accounting controls, and auditing matters promptly. Reports may be made by telephone or in writing to the address and/or telephone number listed below. Reports may be made anonymously. All reports will be treated confidentially to the extent reasonably possible. No one will be subject to retaliation because of a good faith report of suspected misconduct or a complaint or concern regarding any of the accounting matters outlined above.

The Company has established and published on its Web site a Compliance telephone number as well as a P.O. box for receiving written complaints regarding accounting matters from employees or others. The contact information is:

ABC Company

P.O. Box 555

Anytown, USA 12345

Attn: John Smith

Telephone: 1-888-555-1234

INVESTIGATION OF SUSPECTED VIOLATIONS

All reported violations will be investigated promptly and treated confidentially to the extent reasonably possible. It is imperative that reporting persons not conduct their own preliminary investigations. Investigations of alleged violations may involve complex legal issues, and acting on your own may compromise the integrity of an investigation and adversely affect both you and the Company. ...

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