Adopted as of February 15, 2022

Whistleblower Protection Policy: Reporting Suspected Violations of Law or Misconduct

Snowdrop Foundation, Inc. and its affiliated entities are committed to the highest standards of ethical, moral and legal business conduct where associates are free to raise good faith concerns regarding the Snowdrop Foundation business practices, specifically: (1) reporting suspected violations of federal, state or local laws or regulations on the part of the Snowdrop Foundation; (2) providing truthful information in connection with an inquiry or investigation by a court, agency, law enforcement, or other governmental body; and (3) identifying potential violations of any adopted Snowdrop Foundation policies, including the Snowdrop Foundation Code of Ethics and the Snowdrop Foundation Conflict of Interest Policy.

This Whistleblower Protection Policy (this “Policy”) forbids any retaliatory action, including harassment, discrimination, intimidation, or in the case of employees, adverse employment consequences of any kind, to be taken against any individual who, in good faith, reports any action or suspected action taken by or within the Snowdrop Foundation that is illegal, fraudulent or in violation of any adopted Snowdrop Foundation policies, including the Code of Ethics or the Conflict-of-Interest Policy, or who in good faith complains about, or raises a claim or concern about, any type of harassment, retaliation or discrimination prohibited by applicable law or Snowdrop Foundation policy. Retaliation is also prohibited against individuals who are not themselves complainants, but who participate in good faith in an investigation. Any associate (as defined below) who engages in any form of retaliation will be subject to discipline, up to and including termination of employment or removal from a volunteer position. Associates who believe that they or someone they know are being, or have been, retaliated against should immediately report this to his or her supervisor or Board of Directors. The person who is the subject of a report of suspected violation may not be present at or participate in deliberations or votes relating to such report, although the person may provide information as background or answer questions prior to deliberations and voting.

The protections of this Policy extend to any associate who discloses information that the associate reasonably believes is evidence of gross mismanagement of a Federal contract or grant, a gross waste of Federal funds, an abuse of authority relating to a Federal contract or grant, a substantial and specific danger to public health or safety, or a violation of law, rule, or regulation related to a Federal contract (including the competition for or negotiation of a contract) or grant. An associate who believes he or she has been retaliated against for such a disclosure may report this to the Inspector General of the Federal agency concerned, in addition to or instead of his or her supervisor or Chief Legal.

Associates filing a complaint or reporting a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will result in appropriate disciplinary action, up to and including termination or volunteer disqualification.

This Policy must be distributed to all directors, officers, employees and to volunteers who provide substantial services to the Snowdrop Foundation (collectively, “associates”). This Policy, and designates the Board of Directors, to implement this Policy on its behalf. Employees may not participate in any deliberations or voting relating to the administration of this Policy.