Non Retaliation Policy
ZIM is aware of the need to include employees and others in the process of ensuring that they continue to operate ethically, honestly and timely. As a result, the Corporation has formed its Non-Retaliation Policy to ensure (i) the receipt, retention, and treatment of complaints received by the Corporation regarding accounting, internal accounting controls, or auditing matters; and (ii) the confidential, anonymous submission by ZIM employees of concerns regarding questionable accounting or auditing matters.
- ZIM will publish on its web site special mail and e-mail addresses and a telephone number for receiving complaints regarding accounting, internal accounting controls, or auditing matters. In addition, the Corporation has identified a Compliance Officer who is an independent Board Member. Effective August 2003, the Compliance Officer is Mr. Donald Gibbs. Mr. Gibb’s phone number is (609) 234-6010 and his email is firstname.lastname@example.org.
- Copies of all complaints regarding accounting, internal accounting controls or material auditing matters will be sent directly to the Corporation’s independent auditors.
- Copies of all complaints regarding accounting, internal accounting controls, or material auditing matters will also be provided promptly to members of the Audit Committee;.
- All complaints will be tracked on a separate Audit Committee complaints docket.
- The status of the specially docketed complaints will be reported on a quarterly basis to the Audit Committee and, if the Audit Committee so directs, to the full Board.
- The Audit Committee may request special treatment, including the retention of outside counsel or other advisors, for any complaint addressed to it.
- There will be no retaliation to anyone involved in any government investigations relating to the Corporation.
- Employees who file reports or provide evidence which they know to be false or without a reasonable belief in the truth and accuracy of such information will not be protected by the above policy statement and may be subject to disciplinary action, including termination of their employment.
All complaints and concerns will be received and processed by ZIM’s Compliance Officer. When possible, we will acknowledge receipt of your written complaint or concern.
You can report your complaint or concern anonymously or confidentially through the Compliance Officer at the contact information above.
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ZIM Corporate Headquarters
150 Isabella Street, Suite 150
Canada K1S 1V7
Calçada Flor de Lis, 46 2º.And.
Tel: 011 55 11 5505 6868
Fax: 011 55 11 5505 2426