PIPELINE DATA INC. POLICY ON COMMUNICATING ACCOUNTING AND AUDITING RELATED MATTERS TO THE COMPANY

 

Pipeline Data Inc. (PPDA) is committed to the highest standards of financial reporting and in achieving compliance with the applicable securities laws and regulations, accounting standards, accounting controls and audit practices. To help ensure the integrity of financial reports, PPDA has established procedures for the confidential, anonymous submission by PPDA employees of concerns regarding questionable accounting or auditing matters. The purpose of this policy is to enable PPDA to become aware of any fraud or accounting irregularities before they can be detected by PPDA’s internal controls. PPDA’s internal controls and operating procedures are intended to detect, prevent, and deter improper activities regarding accounting, internal accounting controls and auditing matters. However, even the best systems of control cannot provide absolute safeguards against irregularities. PPDA employees have a responsibility to evaluate and report allegations of suspected improper actions involving accounting and auditing matters to appropriate parties.

Expectation

Employees are expected to report allegations of suspected improper activities regarding accounting, internal accounting controls and/or auditing matters. Any employee with a reasonable basis for believing such improper accounting or auditing activities should contact PPDA’s legal counsel at 800-932-5708, or use the Company’s existing internal reporting procedures to leave a confidential and anonymous message within five (5) business days of becoming aware of the improper acts.

Non-employees with reasonable basis for believing such improper accounting or auditing activities has occurred at PPDA can write a letter directly to our Corporate Headquarters at 1515 Hancock Street, Suite 301, Hancock Plaza, Quincy, Massachusetts 02169 for onward delivery to Company’s Legal Counsel.

Employees and others are expected to provide as much specific information as possible including names, dates, and events that took place, as well as describe why the incident may be a violation.

Employer Responsibility

PPDA will review and investigate, as appropriate, reports of improper accounting or auditing activities. PPDA will take prompt and effective action to stop such activities and discipline those responsible.

Reportable Activities

PPDA employees should report improper or questionable activities regarding accounting, internal accounting controls, and/or auditing matters.

Examples of improper or questionable activities include, but are not limited to, the following:

• Fraud or intentional error in the preparation, review or audit of any financial statement or filing of the Company  

• Fraud or intentional error in the recording and maintaining of financial records of the Company  

• Deficiencies in or noncompliance with the Company’s internal accounting controls  

• Misrepresentation or false statements by a senior officer or accountant regarding an accounting matter

Employee Protection

Messages left on the aforementioned website are anonymous and will be dealt with appropriately. An employee who elects to disclose his or her identity will not be discharged, demoted, suspended, threatened, harassed or discriminated against in any way for providing information about an improper act. Any employee that discriminates against someone for reporting an improper act will be subject to disciplinary action that could lead to suspension, transfer or termination.

False Accusations

Any PPDA employee who makes a false allegation with reckless disregard for the truth, that is intended to be disruptive or to cause harm to another individual(s), will face disciplinary and legal proceedings action up to and including termination.