For purposes of section 406 of the Sarbanes-Oxley Act of 2002 and the rules promulgated thereunder, this Honor Code shall be our code of ethics for the Chief Executive Officer, the Chief Financial Officer and Chief Accounting Officer or other persons performing equivalent functions (collectively, the “Senior Financial Officers”). Because the equity shares of AFC® are publicly traded, Senior Financial Officers are held to an especially high set of ethical standards.
WHISTLEBLOWER PROTECTION: REPORTING OF CONCERNS REGARDING ACCOUNTING, INTERNAL ACCOUNTING CONTROLS AND AUDITING MATTERS
In addition to an employee’s responsibility to report Honor Code concerns, all employees are required to report, or cause to be reported, information, and should assist in any investigation by any regulatory or law enforcement agency, elected officials or others responsible for such matters, concerning the following matters:
- wire fraud, mail fraud, bank fraud, securities fraud, any violation of any SEC rule or regulation, or any federal rules relating to fraud against shareholders
- questionable accounting, internal controls, and auditing matters
- conduct that is not honest and ethical, conflicts of interest, and disclosures that are not full, fair, accurate, timely, and understandable
The Audit Committee of the Board of Directors adopted a Whistleblower Policy effective July 17, 2003, on the reporting of concerns regarding accounting, internal accounting controls and auditing matters. This policy is designed to provide a channel of communication for employees and others who have concerns about the conduct of AFC or any of its people, including with respect to AFC’s accounting, internal accounting controls or auditing matters. The policy provides in pertinent part that AFC will not tolerate any discrimination, harassment of or retaliation against an AFC employee who in good faith reports an actual or suspected violation of the policies and laws discussed in this Honor Code or files, causes to be filed, testifies, participates in, or otherwise assists in a proceeding filed or about to be filed regarding any matter discussed in the preceding paragraph regarding the reporting of concerns relating to accounting, internal accounting controls or auditing matters.
Pursuant to section 301 of the Sarbanes-Oxley Act of 2002, such concerns may be communicated directly to the Audit Committee of the Board of Directors or in the same way as any other Honor Code concern as discussed in the preceding section entitled Reporting of Honor Code Concerns, including communicating in a confidential or anonymous manner to the AFC Honor Line at 1.800.245.1491, at any time, sending a letter setting forth your questions or concerns to AFC’s Chief Compliance Officer at 5555 Glenridge Connector NE, Suite 300 Atlanta, GA 30342 or sending an email to email@example.com. Those concerns regarding accounting, internal accounting controls and other auditing matters will be reported to the Board’s Audit Committee.
For more information:
Office of General Counsel