Whistle Blower Policy

Our Commitment to Compliance

Whistleblower policy governs reporting and investigation of allegations of suspected improper accounting activities. Acts of fraud, waste, and abuse are considered a deliberate act or failure to act with the intention of obtaining an unauthorized benefit.
Examples of such conduct include, but are not limited to:

  • Forgery or alteration of documents
  • Unauthorized alteration or manipulation of computer files
  • Fraudulent financial reporting
  • Pursuit of a benefit or advantage in violation of TCF-USA’s Policies and Procedures
  • Misappropriation or misuse of TCF-USA’s resources, such as funds, supplies, or other assets
  • Authorizing or receiving compensation for goods not received or services not performed
  • Authorizing or receiving compensation for hours not worked

TCF-USA is committed to operating in compliance with all applicable laws, rules and regulations, including those concerning accounting and auditing, and prohibits fraudulent practices by any of its board members, officers, or employees. This policy serves to outline procedures for employees to report actions that an employee reasonably believes violate a law or regulation or that constitutes fraud. This policy applies to any matter which is related to TCF-USA’s business. In addition, it is the
objective of TCF-USA to establish a policy that protects any person reporting organizational wrongdoing, from retaliation, harassment, or adverse employment consequences.

Our Policy

Each employee of TCF-USA has an obligation to report in accordance with this Whistleblower Policy any act believed to violate a law or regulation or constitute fraud.

Anyone reporting a concern must act in good faith and have reasonable grounds for believing the information reported indicates a violation of the law, or constitutes an inappropriate accounting or financial practice. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in discipline, up to and including termination of employment.

TCF-USA employees with any concerns or information pertaining to fraud, waste, or abuse are encouraged to speak with someone who can address their concerns properly. In most cases their supervisor is in the best position to address a concern. However, if the employee is not comfortable speaking with the immediate supervisor about the concern, the employee is encouraged to speak with the CEO or board President or anyone in management who they are comfortable in approaching. Supervisors and managers MUST report suspected concerns to the CEO. Allegations of a serious criminal nature or allegations determined to be beyond the scope of TCF-USA management MUST be forwarded to the proper law enforcement agencies.

All reports will be addressed and investigated by CEO. Appropriate corrective action will be recommended to the board, if warranted by the investigation.

This Whistleblower Policy is intended to encourage and enable employees to raise concerns within the organization for investigation and appropriate action. With this goal in mind, no employee who, in good faith, reports a concern shall be subject to retaliation or adverse employment consequences related to whistleblower complaints. Moreover, an employee who retaliates against someone who has reported a concern in good faith is subject to discipline up to and including termination of employment.