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GOVERNANCE | Asking For Help and Reporting Concerns
Our officers and managers accountable for ensuring that the Code is distributed, understood and adhered to. We acknowledge that it is sometimes difficult to know what to do in a particular situation, which is why we encourage open communication. When in doubt, ask. Whenever you have a question or concern or are unsure about the appropriate course of action:
- Please talk with your immediate supervisor. He or she may have the information you need, or may be able to refer the matter to an appropriate source, including legal counsel as circumstances warrant. Your supervisor is responsible for alerting other appropriate corporate personnel as necessary.
- If you are uncomfortable talking with your immediate supervisor, you may also contact any other officer of the company with whom you feel comfortable, any member of the audit committee or legal counsel.
- If you would rather submit your question or concern in writing, you may do so and present it to a corporate office or fax it to our legal counsel 713-615-5615.
For concerns about accounting, auditing, internal controls or financial matters, you may contact an appropriate officer or call the company’s audit committee chairman at 801-231-1505.
Whistle Blower Protection
The company is committed to providing a workplace conducive to open discussion of its business practices. It is our policy to comply with all applicable laws that protect employees against unlawful discrimination or retaliation by their employer as a result of their lawfully reporting information regarding, or their participation in, investigations involving corporate fraud or other wrongdoing by the company or its employees or business partners. All company employees are encouraged to report either orally or in writing to any corporate officer, or to others as discussed above, all evidence of activity by a company employee or business partner that may constitute:
- Instances of corporate fraud
- Unethical business conduct
- Questionable accounting, internal controls and auditing matters
- A violation of law
- A violation of company policy or this Code
- Retaliation for reporting any violation, or
- Substantial and specific danger to the employee’s or public’s health or safety.
We will not retaliate against anyone who, in good faith, notifies us of any of these matters, nor will we tolerate any harassment or intimidation of any employee who reports any such matter. Likewise, no officer, employee, director or agent of the company may retaliate against any company employee for providing information pursuant to a Securities and Exchange Commission, Congressional or other governmental investigation regarding possible violations of law, including but not limited to the following:
- Federal criminal law relating to securities fraud, mail fraud, bank fraud, or wire, radio and television fraud
- Any rule or regulation of the Securities and Exchange Commission
- Any provision of federal or state law relating to fraud against shareholders.
Additionally, we will initiate a prompt investigation following any credible indication that a violation of law or this Code may have occurred. We will also initiate appropriate corrective action as we deem necessary, which may include notifying appropriate authorities.
However, employees who file reports or provide evidence which they know to be false or without a reasonable belief in the truth and accuracy of such information will not be protected by the above policy statement and may be subject to disciplinary action, including termination of their employment.
Any employee who wants to report evidence of alleged improper activity as described should either notify their manager, any corporate officer. Any manager or corporate officer who receives such a report should report it to the appropriate authority or to legal counsel. In instances where the employee is not satisfied with the supervisor or manager’s response, or is uncomfortable for any reason addressing such concerns to their manager, the employee may contact the CFO/compliance officer or legal counsel. If the employee is uncomfortable for any reason contacting any such person, the employee may contact the Audit Committee Chairman of the Company’s Board of Directors. Employees are particularly encouraged to contact the audit committee chairman if the matter concerns accounting, internal accounting controls, or auditing matters. Employees should provide as much specific information as possible including names, dates, places and events that took place, the employee’s perception of why the incident(s) may be a violation, and what action the employee recommends be taken. Anonymous written or telephonic submissions will be accepted. Employees who choose to identify themselves will receive a reply to their report within [20] working days or as soon as practicable thereafter.
Doing the Right Thing - Whistle Blower Process
As articulated in the Gasco Corporate Code of Business Ethics, we adhere to the highest standards of integrity and honesty. Our company’s strong reputation was built on these principles. Managing fraud, workplace abuses, environmental impact and other ethical issues is essential in today’s corporate environment. We are committed to preserving our reputation for ethical conduct and fair dealing, and in support of that commitment, Gasco has retained the services of Ethical Advocate.
As an independent third party vendor, Ethical Advocate provides a state-of-the-art anonymous reporting system. Whether it is about a situation or person, stakeholders, vendors, and employees need to feel secure that their concerns will be seen or heard; something will be done about it; and as a user desires, their anonymity and confidentiality will be maintained.
If you have knowledge of any wrongdoing, we urge you to come forward. You can do so via either of two methods:
https://gasco.ethicaladvocate.com/index.aspx or by phone at: 866-262-5208 Employee Inquiries
If you have a question or concern as to whether specific behavior is a violation of corporate policy, please complete the inquiry form in the document entitled: CORPORATE CODE OF BUSINESS CONDUCT AND ETHICS and return it to the appropriate officer or resource defined above. You may also submit your inquiry anonymously by fax to our compliance officer at 203-319-1911.
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