Whistleblower Protection Policy

The Academy for Teachers, Inc. (the “Corporation”), requires members of the Board of Directors (“Board”), officers, employees, volunteers, and key persons (each, a “Protected Person”) to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the Corporation, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that the Corporation can address and correct inappropriate conduct and actions. This policy is not intended as a vehicle for reporting violations of the Corporation’s applicable human resources policies, problems with co-workers or managers, or for reporting issues related to alleged employment discrimination or sexual or any other form of unlawful harassment, all of which should be dealt with in accordance with the Corporation’s Personnel Policies and Procedures, as it is those policies and procedures that are applicable to such matters.

Reporting Responsibility

It is the responsibility of all Protected Persons to report concerns about suspected violations of law or regulations that govern the Corporation’s operations, including without limitation, fraud, theft, embezzlement, accounting or auditing irregularities, bribery, kickbacks, and misuse of the Corporation’s assets, as well as any violations or suspected violations of high business and personal ethical standards, as such standards relate to the Corporation (each, a “Concern”).

No Retaliation

It is contrary to the values of the Corporation for anyone to retaliate against any Protected Person who in good faith reports a suspected violation of law, such as a complaint of suspected fraud or suspected violation of any regulation governing the operations of the Corporation. Nor shall a Protected Person suffer such retaliation for objecting to, or refusing to participate in, any activity, policy or practice that forms the basis of a complaint. The prohibited retaliation includes, but is not limited to:

• intimidation,

• harassment,

• discrimination,

• adverse employment consequence (including actions or threats to take action that would affect the current or future employment of a former employee or former independent contractor), or

• reporting or threatening to report to U.S. immigration authorities or other government bodies regarding the suspected citizenship or immigration status of a Protected Person or a family or household member of a Protected Person.

An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

Notwithstanding anything contained in this Whistleblower Policy to the contrary, this Whistleblower Policy is not an employment contract and does not modify the employment relationship between the Corporation and its employees, nor does it change the fact that employees of the Corporation are employees at will. Nothing contained in this Whistleblower Policy is intended to provide any Protected Person with any additional rights or causes of action, other than those provided by law.

Reporting Procedure

The Corporation has an open-door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with the Corporation’s President and/or Chair of its Nominating & Governance Committee. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the Corporation’s Compliance Officer (Chief Operations Officer), who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor, or the President, or the organization’s Compliance Officer. Any questions with regard to the scope, interpretation or operation of this Whistleblower Policy should also be directed to the Compliance Officer.

Compliance Officer

The Corporation’s Compliance Officer is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Compliance Officer will advise the President and/or the Board of all complaints and their resolution, and will report at least annually to the Treasurer on compliance activity relating to accounting or alleged financial improprieties.

Accounting and Auditing Matters

The Corporation’s Compliance Officer shall immediately notify the Finance Committee of any concerns or complaint regarding corporate accounting practices, internal controls, or auditing, and work with the committee until the matter is resolved. Promptly upon receipt, the Finance Committee shall evaluate whether a Concern constitutes an Accounting Concern and, if so, shall promptly determine what professional assistance, if any, it needs in order to conduct an investigation. The Finance Committee will be free in its sole discretion to engage outside auditors, counsel or other experts to assist in the investigation and in the analysis of results.

Investigations and Deliberations

The Compliance Officer may delegate the responsibility to investigate a reported complaint to one or more employees of the Corporation or to any other individual, including persons not employed by the Corporation, selected by the Compliance Officer; provided that the Compliance Officer may not delegate such responsibility to an employee or other individual who is the subject of the reported complaint or in a manner that would compromise either the identity of an employee who reported the complaint anonymously or the confidentiality of the complaint or resulting investigation. Employees of the Corporation may not participate in any Board or Nominating & Governance Committee deliberations or voting relating to the administration of this Whistleblower policy, and the person who is the subject of an investigation may not be present in Committee or Board deliberations or vote on the matter relating to the complaint. However, a person who is the subject of an investigation may present information as background or answer questions at a meeting of the Board or Nominating & Governance Committee prior to the commencement of deliberations or voting relating thereto.

Notwithstanding anything herein to the contrary, the scope, manner and parameters of any investigation of a reported complaint shall be determined by the Nominating & Governance Committee in its sole discretion and the Corporation and its employees shall cooperate as necessary in connection with any such investigation.

Acting in Good Faith

Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed may indicate a violation of law and/or ethical standards. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

The Corporation’s Compliance Officer will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

Records

The Corporation, on behalf of the Finance Committee or Nominating & Governance Committee, as applicable, will retain on a strictly confidential basis for a period of seven years (or otherwise as required under the Corporation’s record retention policies in effect from time to time) all records relating to any reported Concern and to the investigation and resolution thereof. All such records are confidential to the Corporation and such records will be considered confidential.

Distribution

The Corporation shall do each of the following:

a) distribute a copy of this Whistleblower Policy to all directors, officers, employees, key persons, and to volunteers who provide substantial services to the corporation;
b)post the Whistleblower Policy on its website; and
c) post notice of employee rights under Labor Law 740 in an accessible and well-lighted place customarily frequented by employees and applicants for employment.

Compliance Officer:

Name: Jeffrey Wills

Title: Chief Operations Officer

Contact: jeff@academyforteachers.org

Policy approved by the Executive Committee on September 9, 2025.