Reporting Complaints on Accounting, Internal Accounting Controls and Auditing Matters
Corporate Governance Procedure I
Policy
New Jersey Resources Corporation and its subsidiaries (the "Company") are committed to conducting its businesses with integrity and in an ethical manner. This procedure offers employees and the public alike the opportunity to notify the Audit Committee of the Board of Directors of the Company of any complaints or allegations regarding accounting, internal accounting controls or auditing matters. While the Company's Code of Conduct includes a procedure for employees to report allegations of wrongdoing, this procedure specifically allows employees to report, on a confidential, anonymous basis, their concerns regarding questionable accounting or auditing matters to the Audit Committee. Consistent with the Company's Code of Conduct, any employee who in good faith reports any such concerns will not be punished or retaliated against in any way.
Procedure
- Reporting Complaints
Employees may continue to report allegations of wrongdoing as outlined in the Company's Code of Conduct. However, members of the public as well as employees may register a complaint concerning accounting, internal accounting controls and auditing matters by calling Ethicspoint, Inc., a toll-free hotline service at 1-866-384-4277. Ethicspoint is an outside agency not affiliated with the Company whose trained, professional personnel will take your call 24 hours a day, seven days a week, 365 days a year. You may also send a complaint by e-mail to www.ethicspoint.com. No matter the method of communication, if you decide the complaint should be treated on an anonymous, confidential basis, your request will be strictly honored. While you will not be asked to identify yourself, you will be assigned a unique "Report Key" and asked to create your own password. Once your report is received you will be advised of a date to check back and find out what has been done regarding the complaint. The Report Key and password will be necessary for you to check on the status of your report and to respond to any questions that may come up during the investigation. - Reviewing the Complaint
All complaints received by Ethicspoint, Inc. will be forwarded to the General Counsel by the next business day. The General Counsel and the Vice President-Internal Audit will review all complaints received with the Chair of the Audit Committee by the end of the subsequent business day. - Conducting the Investigation
Complaints involving the Company's accounting, internal controls, or auditing matters, or concerns regarding questionable accounting or auditing matters will be promptly investigated by one or more of the General Counsel, Vice President-Internal Audit, Chief Financial Officer and Vice President of Corporate Services, (the "Team"), as the Audit Committee Representative (referred to below) deems appropriate.
The Team will conduct its investigation and notify the Audit Committee Chair, or another Audit Committee designated representative (each an "Audit Committee Representative") of the results as quickly as possible. If necessary, the Audit Committee Representative may authorize the use of independent experts to assist in the investigation.
In the event a complaint raises concerns or allegations of a material nature requiring immediate attention; i.e. the revelation of a scheme to immediately defraud the Company of funds or advance knowledge of an intent to violate the law, the Team will dedicate whatever resources and take whatever actions are necessary to attempt to prevent the action and complete the investigation with all due speed. - Reporting to the Audit Committee
A report on all complaints received involving the Company's accounting, internal accounting controls, or auditing matters, or concerns regarding questionable accounting or auditing matters will be reviewed with the full Audit Committee on a monthly basis. The report shall include the results of the investigation and actions taken, if any. Depending on the nature of the complaint, the Audit Committee Representative may convene a meeting of the full Committee immediately. - Retaining Complaints
All complaints involving the Company's accounting, internal accounting controls, or auditing matters, or concerns regarding questionable accounting or auditing matters will be retained by the hotline service for a period of three years. - Procedure Assessment
The Audit Committee shall assess the effectiveness of this procedure on an annual basis and make whatever revisions or amendments it deems appropriate. - Employee Training
Employees will be reminded annually of the procedure during annual Code of Conduct training. - Questions
Any questions regarding this procedure should be addressed to the General Counsel at 1415 Wyckoff Road, Wall, New Jersey 07719 or by calling 732-938-1489. E-mails are welcome as well at mdugan@njresources.com.
Reviewed 5/12/09
- Reporting Complaints
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