Compliance Officer Procedures

Pursuant to the Non-Retaliation Policy of ZIM Corporation, a corporation formed under the laws of Canada (the “Corporation”), the Corporation’s Compliance Officer shall follow the general procedures set forth below for handling any complaints that purport to involve accounting or auditing irregularities:

  • Determine whether the complaint actually pertains to accounting or auditing matters.
  • When possible, acknowledge receipt of the complaint to the reporting individual.
  • Report the complaint to the Corporation’s Audit Committee. The complaint shall be reviewed under the Audit Committee’s direction and oversight. 
  • Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review. 
  • Prompt and appropriate corrective action will be taken when and as warranted in the judgment of the Audit Committee. 
  • Document corrective action. 
  • Report resolution and corrective actions taken or planned to the reporting individual. 
  • Consult with the reporting individual to verify no reprisals were taken for reporting the complaint.
  • Consider appropriate discipline for the individuals found to have engaged in improper conduct. 
  • Report on status of concerns and resolution to Audit Committee and Board of Directors, as appropriate. 
  • Maintain a log of all complaints, tracking their receipt, investigation and resolution and compile a periodic summary report thereof for the Audit Committee.