General provisions
Introduction
One of the core values we uphold at Al-Mustashar Islamic Bank is conducting our business in compliance with applicable laws and regulations, and maintaining transparency and honesty in our dealings with customers, employees, shareholders, partners, suppliers, and competitors. In line with these values, the purpose of publishing this Code of Conduct is to maintain and promote ethical behavior, respect for applicable laws and regulations, and adherence to applicable policies and procedures, following the highest standards of professional integrity. Al-Mustashar Islamic Bank has adopted this Code of Conduct to define the general principles and standards that its management and employees are expected to adhere to. The purpose of publishing this code is to define the ethical framework within which Al-Mustashar Bank operates, and to alert employees to their responsibility to adhere to the standards set forth, including the applicable laws. They must also act in a way that protects the institution's integrity and enhances the bank's ability to fulfill its mission.
Adherence to the Code of Conduct
The Code of Conduct is distributed to all employees of Al-Mustashar Islamic Bank, including managers and employees who sign an acknowledgment that they have received, read, and understood the standards it contains. This code forms the framework for the bank's compliance program and the written policies and procedures followed by each operational department of the bank. Every manager and supervisor at Al-Mustashar Islamic Bank must ensure that all their subordinates understand and adhere to the standards of conduct outlined in this code and respect all policies and procedures related to their work. The term 'employees of Al-Mustashar Islamic Bank' refers to all workers, managers, and employees of the bank. Managers also have the responsibility to set an example and be positive role models for others to follow the Code of Conduct and conduct business according to the highest standards of ethics and professional conduct. Al-Mustashar Islamic Bank expects all its employees to act in accordance with the principles set forth in this code and with the highest ethical standards. Failure to adhere to these principles may result in disciplinary actions, up to and including termination of the employee's contract. Moreover, violating this code is also a violation of the law and may lead to civil or criminal penalties against any employee, supervisor, manager, and/or the bank. The conduct and behavior of employees, both during and outside of working hours, and the impact of this conduct on the bank's reputation, interests, and employees, are among the main criteria that management considers in the promotion mechanism or in determining those eligible for benefits and salary increases, or when imposing sanctions.
Updating the Code of Conduct
This code is merely a summary of the basic rules, principles, and regulations that apply to the activities of Al-Mustashar Islamic Bank. Any question regarding any issue included in this code should be referred to the Compliance Department or the Human Resources Directorate. This code is subject to updates from time to time, and new additions/amendments are communicated to employees through internal memoranda, emails, the internet, or any other means. It is the duty of the bank's employees to be aware of the current rules and procedures applied in their units.
Reporting Existing or Potential Violations
All employees of Al-Mustashar Islamic Bank must report any fraud or attempted fraud, or potential violation of laws or regulations, or bank policies and procedures, especially any unusual operation that does not comply with the nature of the customer's work, or if the employee is asked to perform an inappropriate or illegal act. If an ethical issue or a particular violation is raised before the direct manager and it is believed that the issue was not addressed, it should be raised directly with the Internal Audit Department or the Human Resources Department. Al-Mustashar Islamic Bank encourages its employees to report, in good faith, any existing or potential violation of ethical issues or rules, laws, and regulations, and prohibits any retaliatory action against any individual for raising justified concerns or ethical issues or for reporting actual or suspected violations.
Principle One – General Principles
1.1 Professionalism Employees are expected to act professionally and honestly towards their colleagues, the bank, and its clients, in accordance with applicable laws and regulations. All employees have the right to work in a safe, inclusive environment free from discrimination, harassment, and bullying. 1.2 Best Interest of the Client Employees must prioritize serving the interests of Al-Mustashar Islamic Bank’s clients without undue preference to any individual or group. They must ensure that the bank's clients are aware of the risks arising from the proposed operations, especially if they do not have sufficient experience in such operations. The service must also be suitable for the client and meet their specific needs. 1.3 Avoidance of Conflicts of Interest Employees must avoid circumstances that may result in conflicts of interest or where the bank or an employee might be suspected of not acting independently. Conflicts of interest must be managed fairly and impartially, ensuring that they never occur at the expense of the client. Employees must ensure that their professional and external activities do not cause any conflict of interest. Employees are not permitted to engage in any professional activity outside the bank without obtaining management's approval. 1.4 Banking and Professional Confidentiality Employees must adhere to the principle of banking and professional confidentiality and respect the duty of secrecy to protect business confidentiality and comply with applicable laws and regulations. Confidential information should only be shared with relevant employees when necessary. 1.5 Compliance with Regulatory Requirements To meet legal and compliance obligations, employees must respect both the letter and spirit of the applicable rules and regulations in the places where they work and refrain from engaging in any activity that may constitute a violation of laws and regulations. The bank strives to ensure that all activities carried out by or on behalf of it comply with the laws and regulations in the markets where Al-Mustashar Islamic Bank operates or in any other relevant area. 1.6 Combating Fraud, Money Laundering, and Terrorist Financing Bank employees must combat corruption, fraud, money laundering, and terrorist financing. Relationships with clients should be based on complete knowledge of the client's identity and activities. Employees who suspect money laundering or encounter unusual or suspicious activities must immediately report their suspicions to the Internal Audit and Anti-Money Laundering and Terrorist Financing Reporting Departments or their respective liaison officers.
Principle Two – Professional Ethics
In support of Al-Mustashar Islamic Bank’s commitment to the highest standards of professional ethics and integrity, employees must accurately and honestly represent the bank and refrain from engaging in any activity or project that would deprive any person of their money, property, or services. The following standards are designed to provide the necessary guidance to reflect the bank's high level of professional ethics and integrity. 2.1 Honest/Truthful Communication Al-Mustashar Islamic Bank expects honesty and integrity from individuals in all their statements and while performing their responsibilities. The bank makes every effort to provide its clients with accurate and timely information. No employee may make any false or misleading statements to any client, person, or institution dealing with the bank about the bank's products or services or those of its competitors. 2.2 Marketing, Advertising, and Media Interviews The bank uses marketing and advertising to inform its current and potential clients about the services it provides and to promote the growth and development of its business. The bank will make every effort and knowledge to provide accurate, correct, and comprehensive information in advertising and marketing and to present advertising and marketing materials for regulatory review when needed. Employees must obtain approval from senior management before publishing any materials such as articles, statements, interviews, or any media appearance related to the bank or its interests or the employee's position in the bank. 2.3 Social Media Employees, when using social media for personal or permitted business purposes, whether during working hours or outside, must follow the following general principles: Do not act as an unauthorized spokesperson for Al-Mustashar Islamic Bank. Do not discuss or disclose any confidential or non-public financial information related to the company, or any confidential information regarding the bank’s clients, shareholders, vendors, suppliers, or business partners. 2.4 Misuse of Al-Mustashar Islamic Bank's Information Employees of Al-Mustashar Islamic Bank are prohibited from misusing confidential information related to Al-Mustashar Islamic Bank concerning any person or institution or using any publication, electronic data, document, or computer program or information that conflicts with the bank's or any third party’s interest. All employees of Al-Mustashar Islamic Bank must ensure that they do not copy documents or computer programs for their personal use in violation of intellectual property laws or licensing agreements. Employees of Al-Mustashar Islamic Bank are also prohibited from using confidential information obtained from competitors, including client lists, profit rates, contracts, and other information that could give a competitive advantage to Al-Mustashar Islamic Bank. Employees of Al-Mustashar Islamic Bank must not obtain confidential information about a competitor through illegal means or methods that constitute a breach of any contractual obligations. 2.5 Employee Conduct Gambling and Games of Chance Gambling for money or anything of value is strictly prohibited, and visiting disreputable clubs is never encouraged. Employees should not participate excessively in games of chance. Alcoholic Beverages The bank prohibits the sale or consumption of alcoholic beverages on its premises and prohibits any employee from performing their duties while under the influence of alcohol. Drugs No employee may possess, use, sell, or distribute any drug or prohibited substance. Weapons/Hazardous Materials The possession or use of firearms, lethal weapons, explosives, or any hazardous materials by any employee on bank premises is prohibited. Bribes and Nepotism Managers, officials, and employees should not give, request, or receive bribes. Insider Trading Managers, officials, and employees are prohibited from participating in or supporting any insider trading activities as misuse of insider information undermines the financial system and unfairly harms others in the market. Illegal Activities Involvement of employees or bank workers in activities that are contrary to laws, regulations, or guidelines exposes them to termination of their employment contract. Examples of illegal activities include: Embezzlement. Fraud such as forgery, counterfeiting, and issuing bad checks. Illegal use of funds, revenues, and fees. Misuse of expenses, assets, and liabilities. Attempting to cover up a wrongdoing without reporting it to the manager or supervisor. Engaging in a fight or resorting to any form of harassment, including sexual harassment. Furthermore, any manager, employee, or worker accused of any crime involving breach of trust, fraud, money laundering, or any crime related to drugs or violence or any felony, or entering any behavior improvement program due to these violations, must inform the Human Resources and Internal Audit managers and send a copy to the Compliance Manager. Political Activities Institutional funds may not be used for political contributions. Any employee or worker or manager participating in political activities does so in a personal capacity, not as a representative of the bank. To avoid any possible conclusion that the bank sponsors or supports any political activity, the institution's name or address should not be used in postal correspondences, fundraising campaigns, or identification in any advertisement or publication unless prior written approval is obtained from the Chairman of the Board or the authorized director. Furthermore, the bank's premises should not be used to support any political party, whether through discussing political topics that could cause disagreement between employees and clients or displaying materials supporting political parties.
Principle Three – Confidentiality
Al-Mustashar Islamic Bank is committed to maintaining the confidentiality of customer information, the bank, and other confidential information, in line with applicable legal and ethical standards. Employees of Al-Mustashar Islamic Bank have access to a wide range of confidential and sensitive information related to the bank, which, if disclosed improperly, could harm the bank’s clients and the bank itself. Al-Mustashar Islamic Bank is obliged to protect confidential and sensitive information related to the bank in a manner that prevents its disclosure without authorization. Information relating to clients and the bank is private, non-public information and should never be accessed for non-professional reasons. Employees must protect the confidentiality of the information they obtain during their employment with Al-Mustashar Islamic Bank throughout their employment period and after leaving the job. 3.1 Client Information Al-Mustashar Islamic Bank is entrusted with important information concerning its clients. This information is essential for the bank to provide high-quality products and services and includes personal data and information about the client's plans (merger, capital increase, etc.) and other information considered essential to our clients. We are obligated to maintain any information provided to us by clients in line with the standards of honesty and confidentiality. Employees must refrain from disclosing any personal or confidential information related to clients unless authorized by law or the client. If there is any confusion about whether to keep information confidential or disclose it, employees should consult the Compliance Department or seek advice from the Legal Department. 3.2 Bank Information Information, ideas, systems, products, income projections, and other assets at Al-Mustashar Islamic Bank are critical to the bank's success, so information related to Al-Mustashar Islamic Bank's competitive position or strategies and those related to negotiations with employees or third parties must be protected and not shared except with employees who need to know to perform their work. Employees must strive to maintain this information and protect its value. 3.3 Employee Information Employee files, payroll schedules, disciplinary matters, and similar information are kept confidential, in accordance with the bank's policies and procedures, and employees must ensure that they do not disclose or share this information and protect its value. 3.4 Guidelines for Maintaining Confidentiality Discussing business matters in the presence of unauthorized individuals, either outside the bank or even in another department, can lead to the inadvertent disclosure of confidential information. — Do not discuss confidential matters in elevators, corridors, and other common areas in bank buildings. — Avoid discussing confidential matters in public places such as taxis, restaurants, etc. — If it is necessary to discuss work-related topics in a public place, be careful not to mention any client's name or any other details that might reveal the client's identity or information about a specific transaction. — Do not leave confidential documents on desks, especially overnight or during lunch breaks. — Drafts of documents that do not need to be filed must be shredded. — For sensitive operations such as mergers and acquisitions, tenders, or major financing commitments that have not yet been disclosed, special precautionary measures must be taken, including: Limiting the number of people aware of confidential information and who can access it to a minimum. Using coded names or omitting names and details that can identify the person in drafts and final documents. 3.5 Information Barriers Information barriers are information controls applied within companies to separate people making investment decisions and isolate them from others who are aware of confidential information that may affect those decisions. In addition to the general principles of confidentiality and preventing information leaks outside the bank, there are also important procedures governing the exchange of information within Al-Mustashar Islamic Bank, often referred to as Chinese Walls, which involve blocking sensitive information held by employees in one department of Al-Mustashar Islamic Bank from employees in another department of the bank. Regular client-related information is not transferred from one employee to another within Al-Mustashar Islamic Bank, even if they belong to the same group, unless the latter needs this information for their work. Sensitive information is subject to further controls so that it can only be used for the professional legal purpose for which it was provided and should not be transferred under any circumstances to any person inside or outside Al-Mustashar Islamic Bank who does not have a direct connection to this specific information.
Principle Four – Conflict of Interest
The senior management, committee members, and all employees owe full and absolute loyalty to the bank. Individuals in important positions are not allowed to exploit their positions for personal gain or to help others gain in any way at the bank's expense. All employees of Al-Mustashar Islamic Bank are expected to manage their business in such a way as to avoid any current or potential error that may result from the impact of these activities on business decisions in the bank or from disclosing information about the bank’s business or plans or using it for personal purposes. In relation to this principle (Principle 4), any conflict of interest must be reported. 4.1 External Financial Interests The following is a non-exhaustive list that serves as a guide to the types of activities that Al-Mustashar Islamic Bank employees, or any member of their families, may engage in, which could lead to a conflict of interest: — Ownership, management, or employment in any external institution dealing with Al-Mustashar Islamic Bank. This does not apply to shares or any significant value. Al-Mustashar Islamic Bank, after reviewing the facts, may permit ownership if management deems that this ownership does not negatively affect the bank's interest or the judgment of the person concerned. — Representing Al-Mustashar Islamic Bank by employees in any commercial transaction in which the employee or any member of their family has an interest. — Disclosing or using confidential, private, or internal information related to Al-Mustashar Islamic Bank, especially for personal interest or benefit to the bank’s employees. 4.2 Providing Services to Competing Banks and Businesses No employee of Al-Mustashar Islamic Bank is allowed to perform work or services for any bank or institution dealing with the bank or seeking to deal with the bank outside the normal scope of their employment without the prior written approval of the Chairman of the Board or the authorized director or the approval of the Human Resources Manager (a copy of the approval to be sent to the Compliance Manager and the Internal Audit Department Manager). 4.3 Board Membership — Employees of Al-Mustashar Islamic Bank must obtain written approval from the Chairman of the Board or the authorized director before participating as a member of the board of any institution that may have conflicting interests with Al-Mustashar Islamic Bank. Bank employees who are asked or seek to be part of the board of any institution that does not have conflicting interests with Al-Mustashar Islamic Bank (e.g., civil, non-governmental, charitable, cultural, etc.) do not need to obtain this approval, but they must disclose this. — Al-Mustashar Islamic Bank reserves the right to prohibit its employees from joining any board if such membership conflicts with the bank's higher interests. — The potential impact of participation on the aforementioned board or its lack of effect must be discussed with the Chairman of the Board or the authorized director. 4.4 Remunerations Employees of Al-Mustashar Islamic Bank are encouraged, with permission from their managers, to participate as lecturers in lectures and educational programs, provided that any remuneration or other offerings are submitted to the Human Resources Department Manager for written approval. 4.5 Avoiding Conflicts of Interest Employees must either avoid any conflict of interest or, if a conflict arises, ensure fair treatment of Al-Mustashar Islamic Bank’s clients. In any case, employees must not unduly prefer the bank's interest over the clients' interests. If an Al-Mustashar Islamic Bank employee is aware of a conflict of interest, the employee must take the necessary steps to ensure proper client treatment. There are several ways in which Al-Mustashar Islamic Bank ensures proper client treatment, including disclosing the conflict, although such a step can be limited based on the nature of the client relationship and may be constrained under certain circumstances. Another way Al-Mustashar Islamic Bank manages potential conflicts of interest is through the Information Barriers policy. 4.6 Disclosure of Material Interest If an employee is aware that Al-Mustashar Islamic Bank may have a material interest in a particular commercial transaction, other than earning its regular commission/fees, or if Al-Mustashar Islamic Bank has a conflict of interest in a proposed transaction, the concerned employee must take the necessary steps to ensure appropriate treatment of clients. Below are some examples of what constitutes a material interest: If Al-Mustashar Islamic Bank is writing a report on a company and has a significant business position or strategic interest in the specific company, the bank is considered to have a material interest in publishing the report. If an Al-Mustashar Islamic Bank employee is a shareholder or has another interest in a company and a client of Al-Mustashar Islamic Bank is considering entering into a transaction related to this company, the employee may be considered to have an interest in the transaction. If an Al-Mustashar Islamic Bank employee has a material interest related to a proposed commercial transaction and is aware of this interest, the employee must take reasonable steps to ensure fair treatment of the client who is part of the transaction. One way for Al-Mustashar Islamic Bank to ensure proper client treatment is to disclose the material interest.
Principle Five – Business Relations
Business-related transactions with merchants, contractors, and other third parties must be conducted without offers or requests for gifts, services, inducements, or other considerations in exchange for influencing or assisting in a transaction. These mentioned standards are designed to guide key employees in determining the appropriateness of activities or conduct within the business relationships of Al-Mustashar Islamic Bank, including relationships with merchants, suppliers, contractors, and government entities. Al-Mustashar Islamic Bank wishes to interpret this policy broadly to avoid any inappropriate behavior. In case of any doubt about whether a certain conduct or activity is ethical or appropriate, the Compliance Department should be contacted. 5.1 Gifts and Offerings The bank seeks to maintain and preserve its reputation at all times to avoid any error. Gifts from clients: Employees are prohibited from requesting tips, private offerings, or gifts from clients and from receiving tips or cash offerings. Employees may accept nominal gifts and offerings (i.e., less than 1,000 dinars) from clients if a client wishes to offer a cash gift, the employee should consult with their supervisor and/or the Human Resources Manager. Gifts that affect decision-making: Employees must not accept gifts, services, or other things of value that might influence decisions or specific activities related to Al-Mustashar Islamic Bank. Offering money, services, or any other items of value expected to influence the judgment or decision of any buyer, supplier, client, government employee, or any other person by Al-Mustashar Islamic Bank is strictly prohibited. Any such conduct must be reported to the Human Resources Manager with a copy sent to the Compliance Manager. Gifts from suppliers: Employees may keep a gift from a supplier if the gift has a value not exceeding 1,000 dinars. If the value of the gift exceeds this amount, the bank's Human Resources Manager should be informed, with a copy sent to the Compliance Manager. If an employee is unsure whether to accept or reject a gift, they should consult their supervisor. To the extent possible, the employee should share these gifts with their colleagues. Employees should not accept expensive gifts, invitations to lavish meals or dinners, excessive hospitality, or offers or goods or services worth more than 1,000 dinars. They are also not allowed to accept gifts from suppliers, contractors, or others unless approved by the Human Resources Manager. Invitations from suppliers: Based on a supplier's invitation, an employee may accept food or drinks at the supplier's expense and may occasionally accept invitations to attend a play, sporting events, or others at the supplier's expense. In most cases, a representative of the supplier should be present with the employee. Nothing in this policy should prevent a department manager from setting stricter rules regarding the acceptance of gifts, offerings, or other valuable items. 5.2 Workshops, Seminars, and Training Courses Attendance at local workshops, seminars, or training courses sponsored by an institution is allowed. However, attendance at seminars, workshops, and training courses abroad at the expense of an institution is subject to the approval of the employee’s supervisor and the Human Resources Manager. 5.3 Business Inducements Bank employees should not attempt to gain any benefit or advantage through the improper use of payments, courtesies within the business framework, or any other inducements. They are also prohibited from offering, providing, requesting, or receiving any form of bribe or any other payment. In addition, employees may offer nominal value gifts, hospitality, or lunch or dinner invitations to clients or current or potential partners and others, as long as these activities are legitimate, reasonable, and in line with applicable laws.
Principle Six – Protecting Bank Assets
All employees must work to protect the bank's assets by using the bank’s resources efficiently and accurately and appropriately reporting their financial status. The mentioned standards are designed to guide key employees by highlighting the bank’s expectations related to activities or conduct that may affect the bank’s financial position or that reflect a reasonable use of assets. 6.1 Internal Controls Al-Mustashar Islamic Bank has established control standards and procedures to ensure the protection and proper use of assets and to ensure the accuracy of all records and reports. All citizens share the responsibility of maintaining and adhering to the required internal control procedures. 6.2 Financial Transactions and Reporting All Al-Mustashar Islamic Bank transactions must be executed according to the general or specific management guidelines. All bank books and records must be kept according to approved accounting standards, except where legal standards may apply. All transactions and assets must be fully and accurately recorded in the bank’s books and records. No payment should be approved, requested, or completed with the intent or basis of using it for any purpose other than that stated in the payment supporting documents. All financial reports, accounting records, and other reports, expense accounts, schedules, and other documents must accurately and clearly represent the facts or the true nature of the relevant transaction. Incorrect or falsified accounting or documentation or financial reporting is against Al-Mustashar Islamic Bank’s policy and conflicts with applicable laws. 6.3 Accuracy, Retention, and Disposal of Documents and Records Employees are responsible for the accuracy and precision of Al-Mustashar Islamic Bank’s documents and records, not only to comply with legal and regulatory requirements but also to ensure the availability of records to defend the bank's operations and activities. No one may alter or falsify information on any record or document. Business records must be maintained, preserved, or destroyed according to applicable laws and the bank's policies and procedures. 6.4 Communication and Communication Systems All communication systems, email, internet access, fax, telephone service, or voicemail are considered the bank's property and are primarily used for business purposes. Limited and reasonable personal use of the bank's communication systems is permitted; however, these means should not be considered private. Customer information should not be transmitted in any way where confidentiality and security are not guaranteed. In compliance with applicable laws and the bank's policies and procedures, Al-Mustashar Islamic Bank reserves the right to periodically access, monitor, and disclose the contents of its communication systems. Al-Mustashar Islamic Bank employees may not use communication systems or internet access in the workplace to display, store, transmit, download, or distribute any harmful materials, whether knowingly or due to negligence or recklessness. Additionally, Al-Mustashar Islamic Bank's communication devices may not be used to send chain letters, personal messages, or copyrighted materials. They are also not used for job searches. Employees who misuse the bank's communication devices or who excessively use them for non-business purposes may be deprived of these privileges and face disciplinary measures in accordance with the bank's policy, noting that these steps may include dismissal from service. 6.5 Travel and Entertainment Travel and entertainment expenses should be consistent with the employee's responsibilities, the institution's needs, and resources. The bank's policy states that employees should not incur financial loss or gain financially as a result of a business trip. Employees must use the bank's assets prudently and manage them with the utmost care as if they were their property. 6.6 Use of Bank Assets All employees are expected to refrain from converting Al-Mustashar Islamic Bank’s assets to personal use. All bank property and activities must be conducted for the benefit of Al-Mustashar Islamic Bank and not for any employee's personal interest. Employees are prohibited from unauthorized use of bank equipment or taking it, and this applies to materials, services, and others. Before engaging in any activity that generates revenue for the employee or using bank equipment, materials, or services for personal or non-business purposes, employees must obtain approval from the Human Resources Manager (with a copy sent to the Compliance Department Manager). 6.7 Respect for Community and Environment Bank employees have a responsibility to minimize the impact of our operations on the environment by managing the resources we use in our operations, raising employee awareness about the importance of caring for the environment, and working with our clients to minimize risks. All employees must also respect human rights affected by our dealings with employees, suppliers, and customers.
Principle Seven – Whistleblower Policy
The bank requires employees to immediately report any illegal activities, alleged or suspected violations of this Code of Conduct, to preserve a culture of ethical conduct, integrity, and transparency. 7.1 Transferring Complaints All bank employees must report any suspicious transactions or alleged violations of this Code of Conduct or any other issues. Complaints can be sent to the Head of Internal Audit at the group in confidence or anonymously via email to the address audit@mib.iq. If the complaint is written and sent by mail, the employee must write the phrase 'Private and Confidential' on the envelope. If the employee wishes to discuss the matter verbally, they should indicate this on the envelope and include a phone number where they can be contacted if necessary. The complaint should be based, as much as possible, on facts, not conjecture or assumptions, and should contain the most specific information possible to conduct an appropriate evaluation. The complaint should clearly describe the alleged violation or concern and include all the information the employee is aware of regarding the allegation or concern. 7.2 Protecting Whistleblowers The bank requires its employees to adhere to the letter and spirit of the law while providing protection to employees who assist authorities in investigating legal violations. The bank prohibits the dismissal, demotion, suspension, threatening, harassment, or discriminatory treatment of any employee if (A) this employee provided information during an investigation, or (B) filed any lawsuit related to violating any fraud law, gave testimony, or participated in or assisted in any way, when this information is provided to a person with authority over the employee or the authority to investigate misconduct, discover it, or terminate it. Disciplinary action will be taken against any official, manager, or employee who retaliates against any employee who reports, in good faith, confirmed or suspected violations of the code or conduct, up to and including dismissal from employment. However, the above policy will not provide protection to employees who submit reports or provide evidence that they know to be false or are not reasonably sure of their accuracy, and disciplinary action may be taken against them, up to and including dismissal from employment.