Whistleblower Policy and Procedures
Accounting and Auditing Matters
This policy and the related procedures apply to all employees of
- General Policy
It is Glatfelter's policy that any employee of the company may
submit a good faith complaint about business conduct in general (Code
of Business Conduct (1.67 MB PDF),
p. 20) and/or accounting or auditing matters in particular, to the
management of the Company without fear of dismissal or retaliation
of any kind.
- Accounting and
Glatfelter is committed to achieving and maintaining compliance with
all applicable securities laws and regulations, accounting
standards, accounting controls and audit practices. The Audit
Committee will oversee treatment of employee concerns in this area.
In order to facilitate the reporting of employee complaints, the
Audit Committee has established the following procedures for (1) the
receipt, retention and treatment of complaints regarding accounting,
internal accounting controls, or auditing matters ("Accounting
Matters") and (2) the anonymous submission by employees of concerns
regarding questionable accounting or auditing matters.
- Receipt of
Employees with concerns regarding Accounting Matters may report
their concerns to the Director of Policy & Compliance, any Attorney
of the Legal Department or on an anonymous basis to the Integrity
Helpline at 1-800-346-1676.
Scope of Matters Covered
These procedures relate to employee complaints relating to any
questionable Accounting Matters, including, without limitation, the
- fraud or deliberate error in the preparation, evaluation, review
or audit of any financial statement of the Company;
- fraud or deliberate error in the recording and maintaining of
financial records of the Company;
- deficiencies in or noncompliance with the Company's internal
- misrepresentation of false statement to or by a senior officer
or accountant regarding a matter contained in the financial records,
financial reports or audit reports of the Company; or
- deviation from full and fair reporting of the Company's
Treatment of Complaints
Upon receipt of a complaint, the Director of Policy & Compliance will
determine whether the complaint actually pertains to Accounting Matters
and when possible, acknowledge receipt of the complaint to sender.
- Complaints made through the Integrity Helpline will be reported
immediately to the Director of Policy & Compliance and the Legal
Department. The caller may remain anonymous and will receive a
personal identification number assigned to the compliant and will be
advised that an answer will be forthcoming within a certain time
- If it is determined that a Complaint relates to Accounting
Matters, the Director of Policy & Compliance will notify the
Chairman of the Audit Committee as soon as reasonably practicable.
- Complaints relating to Accounting Matters will be reviewed under
Audit Committee direction and oversight by the Director of Policy &
Compliance, any Attorney of the Legal Department, the Internal
Auditor or such other persons as the Audit Committee determines to
be appropriate from time to time. Confidentiality will be maintained
to the fullest extent possible, consistent with the need to conduct
an adequate investigation.
- Prompt and appropriate corrective action will be taken when and
as warranted in the judgment of the Audit Committee
- The Company will not discharge, demote, suspend, threaten,
harass or in any manner discriminate against any employee based upon
any lawful actions of such employee with respect to good faith
reporting of complaints regarding Accounting Matters or otherwise as
specified in Section 806 of the Sarbanes-Oxley Act of 2002.
- Reporting and Retention of Complaints and Investigations
The Legal Department will maintain a log of all complaints including
complaints not directly related to Accounting Matters, tracking their
receipt, investigation and resolution and shall prepare a periodic summary
report thereof for the Audit Committee. Copies of complaints and such log
will be maintained in accordance with all applicable laws and regulations.