Whistleblowing Policy

Purpose

This Whistleblowing Policy aims to provide employees, contractors, suppliers, and other stakeholders with guidelines for reporting unethical behavior, illegal activities, or any form of misconduct within UNIVERSAL FINANCIAL ASSOCIATES, INC. (the “Company”). The policy ensures that concerns are raised in a confidential and secure manner, protecting the rights of the whistleblower while maintaining the integrity of the investigation process.

Scope

This policy applies to all employees, officers, directors, contractors, suppliers, and any other third parties acting on behalf of the Company. It covers a wide range of issues including but not limited to:

  • Fraud

  • Corruption

  • Health and safety violations

  • Environmental damage

  • Breach of company policies

  • Financial misconduct

  • Harassment or discrimination

  • Violation of laws and regulations

Definitions

  • Whistleblower: An individual who reports misconduct or unethical behavior.

  • Misconduct: Any action that violates legal, ethical, or professional standards, including company policies and procedures.

  • Retaliation: Any adverse action taken against a whistleblower as a result of their report.

Reporting Channels

Whistleblowers can report concerns through the following channels:
Mail
Send written reports to UNIVERSAL FINANCIAL ASSOCIATES, INC., Attn: Whistleblower Program.

Confidentiality

The Company is committed to maintaining the confidentiality of the whistleblower and the information provided. Reports can be made anonymously if the whistleblower chooses. The identity of the whistleblower will not be disclosed without their consent, except where required by law.

Protection Against Retaliation

The Company strictly prohibits retaliation against any whistleblower. Retaliation can include but is not limited to:

  • Dismissal or demotion
  • Disciplinary action
  • Harassment or bullying
  • Unfavorable changes in employment conditions

Any individual found to be engaging in retaliatory actions will face disciplinary measures, which may include termination of employment. 

Investigation Process

Upon receiving a report, the Company will:
Acknowledge receipt of the report within seven (7) days.
Conduct a preliminary assessment to determine the validity of the report.
Assign the investigation to a designated team or individual, who will investigate promptly and thoroughly.
Maintain records of the investigation process, findings, and conclusions.
Communicate the outcome of the investigation to the whistleblower, if their identity is known and if it is appropriate to do so.

False Reporting

Reports made in good faith, even if they turn out to be unfounded, are protected under this policy. However, any individual found to be knowingly making false or malicious reports will be subject to disciplinary action.

Training and Awareness

The Company will provide regular training to employees on the whistleblowing policy, including how to recognize and report misconduct. Awareness programs will be conducted to ensure that all stakeholders understand the importance of whistleblowing and the protection provided under this policy.

Review and Monitoring

This policy will be reviewed annually or as needed to ensure it remains effective and aligned with legal and regulatory requirements. The Company will monitor the implementation of this policy and make necessary adjustments to address any issues or improve processes. 

Contact Information
For any questions or concerns regarding this Policy, please contact:
Universal Financial Associates Compliance Team

compliance@universalfinancialassociates.com

By implementing this Whistleblowing Policy, UNIVERSAL FINANCIAL ASSOCIATES, INC. demonstrates its commitment to ethical behavior, transparency, and a safe environment for reporting misconduct.