Whistleblower Policy for Online Intergroup of Alcoholics Anonymous, Inc.

Office of Intergroup Alcoholics Anonymous, Inc. (“OIAA” or, the “Non-Profit”) requires its trustees,
officers, employees, and volunteers (each, a “Non-Profit Member”) to observe high standards of
business and personal ethics in the conduct of their duties and responsibilities. As trustees, officers,
employees, volunteers, and representatives of the Non-Profit, we must practice honesty and integrity in
fulfilling our responsibilities and comply with all applicable laws and regulations.

ARTICLE I PURPOSE

Section I.01 The purpose of this whistleblower policy (the “Policy”) is to:

(a) Encourage and enable Non-Profit Members to raise concerns regarding suspected illegal or unethical conduct or practices, or violations of the Non-Profit’s policies on a confidential and, if desired, anonymous basis.

(b) Protect Non-Profit Members from retaliation for raising such concerns.

(i) receive and investigate reported concerns; and
(ii) address and correct inappropriate conduct and actions.

ARTICLE II REPORTING RESPONSIBILITY

Section II.01 Reporting Responsibility. Each Non-Profit Member has the responsibility to report in good faith any concerns about actual or suspected violations of the Non-Profit’s policies or any federal, state, or municipal law or regulation governing the Non-Profit’s operations (each, a “Concern”). Appropriate subjects to report under this Policy include but are not limited to financial improprieties, accounting or audit matters, ethical violations, or other similar illegal or improper practices, such as:

(a) Fraud.
(b) Theft.
(c) Embezzlement.
(d) Bribery or kickbacks.
(e) Misuse of the Non-Profit’s assets.
(f) Undisclosed conflicts of interest/ bullying, harassment including gender- based harassment, racism/ not following principles established in the bylaws

Section II.02 Acting in Good Faith. Anyone reporting a Concern must act in good faith and
have reasonable grounds for believing the information disclosed indicates a violation of law and/or
ethical standards. Any unfounded allegation that proves to have been made maliciously, recklessly, or
knowingly to be false will be viewed as a serious offense and result in disciplinary action up to and
including termination of employment or volunteer status.

Section II.03 Other Types of Concerns. Non-Profit Members use the Non-Profit’s existing
complaint procedures and mechanisms to report other issues not covered by Section 2.01 of this Policy,
unless those channels are themselves implicated in wrongdoing. This Policy is not intended to provide a means of appealing the outcomes resulting from those other mechanisms.

ARTICLE III NO RETALIATION
Section III.01 No Non-Profit Member who in good faith reports a Concern or participates in a
review or investigation of a Concern shall be subject to harassment, retaliation, or, in the case of an
employee, adverse employment consequences because of such report or participation. This protection
extends to Non-Profit Members who report in good faith, even if the allegations are, after an
investigation, not substantiated.

Section III.02 No Non-Profit Member will be subject to liability or retaliation for disclosing a
trade secret in compliance with 18 U.S.C. § 1833 either:
(a) In confidence to a federal, state, or local government official or to an attorney
solely for the purpose of reporting or investigating a Concern; or
(b) In a complaint or other document filed in a lawsuit or other proceeding under seal.

Section III.03 Any Non-Profit Member who retaliates against someone who in good faith has
reported or participated in a review or investigation of a Concern will be subject to discipline, up to and
including termination of employment or volunteer status.

Section III.04 Anyone who believes that a Non-Profit Member has been subject to harassment,
retaliation, or adverse employment consequences as a result of making a good faith report or participating in a review or investigation of a Concern should contact a member of the board listed in Article V of this Policy.

ARTICLE IV CONFIDENTIALITY
Section IV.01 The Non-Profit encourages anyone reporting a Concern to identify themselves in
order to facilitate the investigation of the Concern. However, Concerns may be submitted on a
confidential and/or anonymous basis. The Non-Profit shall take reasonable steps to protect the identity
of the Non-Profit Member, and shall keep reports of Concerns confidential to the extent possible,
consistent with the need to conduct an adequate investigation.

ARTICLE V REPORTING PROCEDURES
Section V.01 Prompt Reporting. All Concerns should be reported as soon as practicable
consistent with this Policy.

Section V.02 Reporting Concerns.
(a) Employees or volunteers should first discuss the Concern with their direct supervisors or their committee chairs.
(i) The employee or volunteer reasonably believes that the supervisor will disregard or otherwise not fairly consider the Concern.
(ii) The supervisor is a subject of the Concern.
(iii) The employee or volunteer does not feel comfortable discussing the Concern with the supervisor.

(b) Concerns should be reported in writing to any member of the Board of Trustees
the Non-profit Member feels comfortable in voicing their concerns. (chair@aa-intergroup.org;
vice-chair@aa-intergroup.org; secretary@aa-intergroup.org; treasurer@aa-intergroup.org;
tech.chair@aa-intergroup.org; trustee.at.large@aa-intergroup.org; international.trustee@aa-
intergroup.org) . When reporting Concerns, the Non-Profit Member should describe in detail the
specific facts that support the report.

Section V.03 Questions. Any questions relating to the scope, interpretation, or operation of this
Policy should be directed to any member of the Board of Trustees.

Section V.04 Investigation of Reported Concerns.
(a) Compliance. Board of Trustees: The Board of Trustees is responsible for:
(i) Promptly investigating or overseeing the investigation of each reported Concern.
(ii) Advising the other members of the Board of Trustees of each reported Concern.
(iii) Reporting compliance activity to the full Board of Trustees at each regularly scheduled Board meeting.

(b) Acknowledgment of Receipt. Any supervisor, manager, committee chair or Board member who receives a report of a Concern must promptly notify the whole Board of Trustees of such report in writing. The contacted Member of the Board of Trustees shall notify the reporting individual and acknowledge receipt of each reported Concern within five (5) business days, unless the report was submitted anonymously.

(c) Investigation. The Board of Trustees shall determine who shall conduct a prompt,
discreet, and objective review or investigation based on the submitted report. A full investigation
may not be possible if a report made anonymously is vague or general. If deemed necessary theBoard Member designated to lead the investigation upon the recommendation of the Board of
Trustees, may engage legal counsel, accountants, or other experts to assist in the investigation.
The Board Member chosen to lead the investigation may delegate the investigation
responsibilities to any Board committee or other individual, including third parties, as long as:
(i) The delegate is not a subject of the reported Concern.
(ii) The delegation does not compromise the identity of the Non-Profit Member who reported anonymously or confidentially.

(d) Resolution. The Board Member designated to investigate shall:

(i) Recommend appropriate corrective action to the Board of Trustees, if warranted by the investigation.

(ii) Oversee the implementation of a resolution based on the determination of the Board.

(iii) Follow up with the reporting individual, if possible, for closure of the reported Concern.

(e) Accounting and Auditing Matters. The Board Member designated by the board to investigate an accounting or auditing matter must be outside of the Finance Committee and shall immediately notify the Board of Trustees of any Concerns regarding accounting practices, internal controls, or auditing, and shall work with the Board of Trustees until the matter is Resolved.

ARTICLE VI PERIODIC REVIEWS
Section VI.01 To ensure that the Non-Profit operates in a manner consistent with charitable purposes and does not engage in activities that could jeopardize its reputation or tax-exempt status, the Board of Trustees shall conduct periodic reviews of this Policy.

ARTICLE VII MISCELLANEOUS
Section VII.01 The Non-Profit retains any records related to the investigation and resolution of a reported Concern as required by the Non-Profit’s Records Retention and Destruction Policy. All such records are considered privileged and strictly confidential.
Section VII.02 This Policy shall be distributed to all Non-Profit Members. Failure to comply with the Policy may result in discipline or removal, up to and including termination of employment or office.

Section VII.03 This Policy was adopted by the OIAA’s Board of Trustees at its meeting on January 26, 2025.

ARTICLE VIII ACKNOWLEDGMENT
Section VIII.01 The undersigned acknowledges that on the date set forth below, the undersigned received a copy of OIAA’s Whistleblower Policy (this “Policy”) and has read it, understood it, and agreed to comply with it. The undersigned understands that the Non-Profit has the maximum discretion permitted by law to interpret, administer, change, modify, or delete this Policy at any time with or without notice. No statement or representation by a supervisor or manager or any other employee, whether oral or written, can supplement or modify this Policy. Changes can be made only if approved in writing by the Board of Trustees of the Non-Profit. The undersigned also understands that any delay or failure by the Non-Profit to enforce any policy or rule will not constitute a waiver of the Non-Profit’s right to do so in the future. The undersigned understands that neither this policy nor any other communication by management representatives or any other employee, whether oral or written, is intended in any way to create a contract of employment.

For employees only: The undersigned understands that, unless the undersigned has a written
employment agreement signed by an authorized representative of the Non-Profit, the undersigned is
employed at will and this Policy does not modify my at-will employment status. If the undersigned has
a written employment agreement signed by an authorized representative of the Non-Profit and this Policy conflicts with the terms of my employment agreement, the undersigned understands that the terms of their employment agreement will control.