General Statement of Purpose
Sequential Brands Group, Inc. (the “Company”) is an organization with strong values of responsibility and integrity. The Company is committed to an environment where open, honest communications are the expectation, not the exception. In an effort to further this commitment, this policy:
(i) establishes guidance for the receipt, retention, and treatment of verbal or written reports received by the Company regarding accounting, internal controls, auditing matters, disclosure, fraud and unethical business practices, whether submitted by Company employees or third parties (“Reports”);
(ii) establishes guidance for providing Company employees a means to make Reports in a confidential and anonymous manner; and
(iii) makes clear the Company’s intention to discipline, up to and including termination of employment, any person determined to have engaged in retaliatory behavior.
This policy and information regarding problem resolution resources, shall be provided to the Company’s employees and made generally available through the Company website and / or intranet. The Company has engaged
(a) NAVEX Global, an independent ethics and compliance company to administer the Company’s Ethics and Compliance Hotline,
(b) the Chief Financial Officer, or
(b) the Chairman of the Audit Committee of the Board of Directors to be the recipients of all the Reports filed under this policy and has designated the Chief Financial Officer to coordinate any necessary Company action. Any Report received by NAVEX Global will be forwarded to the appropriate party, which would be either the Chief Financial Officer or the Chairman of the Audit Committee. Any Report received by a Company officer, director, or employee from a non-Company source should be immediately forwarded to NAVEX Global.
All Reports will be taken seriously and addressed promptly, discreetly and professionally. Reports may be submitted anonymously or to the direct supervisor of the employee or to the Chief Financial Officer. Should a person desire to remain anonymous, that desire will be respected. Discussions and documentation regarding reports will be kept in strict confidence to the extent appropriate or permitted by policy or law. Should the person submitting the Report identify himself or herself, the recipient of the Report will communicate to the employee the steps to be taken to address the Report and the results of any Company actions initiated. This confidential report process may be used either to submit a new Report, or to address an employee’s previous Report, which such employee does not feel was adequately resolved.
Retaliation against any employee that files a Report or voices a concern under this policy is strictly prohibited. Employees determined to have engaged in retaliatory behavior or who fail to maintain an employee’s anonymity if requested may be subject to discipline, which could include termination of employment. Any employee who feels that he or she has been subjected to any behavior that violates this policy should immediately report such behavior to his or her supervisor, the Chief Financial Officer, NAVEX Global or the Chairman of the Audit Committee. Please note however, that employees who knowingly file misleading or false reports, or without a reasonable belief as to truth or accuracy, will not be protected by this policy and may be subject to discipline, including termination of employment.
Audit Committee Review of Reports
A summary of reports received under this policy will be communicated to the Audit Committee on a quarterly basis (or a more frequent basis should conditions warrant more timely action). If you would like to file a confidential report under the terms of this policy, please contact NAVEX Global at (844) 284 5815 or by filing a report using our confidential, Internet reporting tool at www.sbg.ethicspoint.com. This website is staffed by our vendor partner NAVEX Global and anonymity is guaranteed.