Commitment to Ethics

 

Afognak Native Corporation, Alutiiq, LLC, and their subsidiaries embrace ethical conduct as a value of the highest order. They are committed to upholding strict standards of ethical, regulatory and legal behavior, and they operate a formal corporate Ethics and Compliance Program. The Program and its supporting documentation incorporate traditional Alutiiq values of harmony, appreciation and respect, efficiency, communication, trust, heritage and culture.

The Afognak Code of Ethics and Business Conduct applies to all employees of Afognak Native Corporation, Alutiiq, LLC, and their subsidiaries, and it summarizes the guiding virtues and principles to which the companies and their employees strictly adhere. Equally, they expect agents, consultants, contractors, subcontractors, representatives and vendors of these companies to adhere to and be guided by similar stringent ethical standards.

Afognak Code of Ethics and Business Conduct

Afognak Native Corporation strives to create and maintain a consistent corporate cultural norm of ethical conduct, and this culture of ethical conduct flows down through Alutiiq, LLC and their subsidiaries. The companies have implemented a multi-media approach to distributing the Afognak Code of Ethics and Business Conduct in a proactive effort to ensure the companies’ employees become, and stay, well informed about the code. They update the Code annually, provide it to new hires, post it on the internet internally and externally, provide it through the Alutiiq iPhone application, mail or email it to every employee annually, reference it in their Ethics and Compliance posters located throughout employee common areas, and require annual employee training on the Code.

Silent Whistle: Reporting Violations

The companies are committed to providing a workplace conducive to open discussion of their business practices. It is their policy for anyone, to include all employees, subcontractors, vendors and customers of Afognak Native Corporation, Alutiiq, LLC, and their subsidiaries, aware of a violation of the Code of Conduct, internal policies and procedures, or any legal requirement, to report a possible violation. The companies will not tolerate retaliation against anyone for such reporting. Company policy strictly complies with all laws that protect employees from discrimination or retaliation by any employee as a result of their lawfully and truthfully reporting information regarding, or their participating in, investigations involving allegations of corporate fraud or other violations by Afognak Native Corporation, Alutiiq, LLC, or their subsidiaries.

Reports may be made via phone or email to the company’s third-party employee Hotline at 1-800-829-8547 or http://afognak.silentwhistle.com.

Employee Training on Ethics and Business Conduct

Afognak Native Corporation and Alutiiq, LLC developed and implemented Alutiiq University as an online corporate training resource available to all employees of Afognak Native Corporation, Alutiiq, LLC, and their subsidiaries. This site features interactive tutorials that educate employees on harassment, ethics and compliance, safety, supervising employees, company history, computer applications, and other topics.