Whistleblower Protection Policy
ACAMS expects its oﬀicers, directors and employees to adhere to the highest standards ofbusiness and personal ethics in the conduct of their duties and responsibilities. As employees ofACAMS, we must practice honesty and integrity in fulfilling our responsibilities and comply withall applicable laws and regulations.
“ACAMS” as used herein, shall be inclusive of Alert Global Media, LLC, the sole member of
Association of Certified Anti-Money Laundering Specialists, LLC, and its and their direct andindirect wholly owned subsidiaries.

Reporting Responsibility
This Whistleblower Protection Policy is intended to encourage and enable internal and external
stakeholders to raise serious concerns so that ACAMS can address and correct inappropriate
conduct and actions. It is the responsibility of all ACAMS oﬀicers, directors and employees toreport concerns about violations of ACAMS’s Code of Conduct or suspected violations of law or
regulations that govern ACAMS’s operations.

No Retaliation
It is contrary to the values of ACAMS for anyone to retaliate against any board member, oﬀicer, andemployee who in good faith reports an ethics violation, or a suspected violation of law, such as acomplaint of discrimination, or suspected fraud, or suspected violation of any regulation
governing the operations of ACAMS. An employee who retaliates against someone who hasreported a violation in good faith is subject to discipline up to and including termination ofemployment.

Reporting Procedure
ACAMS 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 yoursupervisor or you are not satisfied with your supervisor’s response, you are encouraged to speakwith Legal & Compliance or Human Resources team members.

Employees can also report any concerns or violation anonymously through the following
channels:

Acting in Good Faith
Anyone filing a written or oral complaint concerning 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 to have been made maliciously or knowingly to befalse will be viewed as a serious disciplinary oﬀense.

Conﬁdentiality
Violations or suspected violations may be submitted on a confidential basis by the complainant.
Confidentially submitted reports of violations or suspected violations will be kept confidential tothe extent possible, consistent with the need to conduct a proper investigation.
The following information will be kept as confidentially as possible. Where applicable law
requires absolute confidentiality, this information will be kept absolutely confidential:
i.
ii.
iii.

Your identity;
The identity of the person or persons targeted in your report and of any third party
mentioned in the report;
And more generally, the information contained in your report, i.e., the conduct forming thebasis of the report.

You may be asked to waive confidentiality in order to further facilitate an investigation. You will
have no obligation to waive confidentiality and any decision to maintain confidentiality will not
subject you to disciplinary action.

Handling of Reported Violations
ACAMS will acknowledge receipt of the reported violation or suspected violation as soon aspossible. Where applicable law requires that ACAMS acknowledge receipt of a complaint within aset period of time, ACAMS shall acknowledge the complaint no later than seven (7) days after
receipt of the complaint. ACAMS’ acknowledgement of a complaint does not mean ACAMS
necessarily agrees with the facts alleged.
Investigation of a complaint is the second stage in the process. ACAMS will promptly investigate allcomplaints in order to determine their veracity and any subsequent action to be taken (internal
investigation, judicial procedure, etc.). ACAMS will also determine any remedial action that shouldbe implemented. The Legal & Compliance team may carry out the investigation by itself, throughinternal resources, or by engaging external counsel.
Additionally, information may be communicated throughout the investigation.
ACAMS will communicate any findings applicable to the complainant to the complainant. Where
applicable law requires that a complainant be informed of the results of an investigation,complainant will be informed of the results of the investigation no later than three months after
the conclusion of the investigation. The complainant will also be informed if the matter is closed,or the facts alleged are found to be inaccurate.