Whistleblower Policy

1. Purpose

Wounded Warriors (the "Organization") requires directors, officers, employees, and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of the Organization must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations. This policy outlines a procedure for those individuals to report actions suspected to be in violation of this standard.

2. Scope

This policy applies to all directors, officers, employees, volunteers, contractors, and consultants of the Organization. It covers any suspected wrongful conduct, including but not limited to:

• Fraud, theft, embezzlement, or misappropriation of assets;
• Violation of federal, state, or local law or regulation;
• Falsification or improper alteration of records;
• Improper use of charitable assets or donor funds;
• Harassment, discrimination, or retaliation;
• Violations of the Organization's Conflict of Interest Policy, Records Retention Policy, Donor Privacy Policy, or Gift Acceptance Policy;
• Substantial and specific danger to public health or safety;
• Any deliberate action that may jeopardize the Organization's tax-exempt status.

3. Reporting Responsibility

It is the responsibility of all directors, officers, employees, and volunteers to comply with the Organization's Code of Ethics and to report violations or suspected violations in accordance with this policy.

4. No Retaliation

5. Reporting Procedure

1. Preferred channel. Reports should be submitted in writing to the Treasurer of the Board of Directors, who serves as the Compliance Officer. Email: info@warriorsfund.org (mark subject line "CONFIDENTIAL — COMPLIANCE REPORT"). Mail: Compliance Officer, Warriors Fund, 1790 Hughes Landing Blvd, Suite 400, The Woodlands, TX 77380.
2. If the report concerns the Treasurer or Executive Director, submit directly to the Board Chair using the same channels above with the subject line "CONFIDENTIAL — BOARD CHAIR REPORT."
3. Anonymous reports are accepted, but the Organization's ability to investigate may be limited without the ability to request follow-up information.
4. Acknowledgment. The Compliance Officer will acknowledge receipt of the report within ten (10) business days.

6. Handling of Reports

1. The Compliance Officer will initiate a prompt and thorough investigation. The scope and nature of the investigation will be determined by the facts of the report.
2. The Compliance Officer may consult with, and delegate investigative steps to, the Board Chair, outside counsel, an independent accountant, or the full Board of Directors as appropriate.
3. Confidentiality will be maintained to the fullest extent consistent with conducting a thorough investigation, meeting the Organization's legal obligations, and protecting the rights of all individuals involved.
4. Investigation findings and any corrective action will be reported to the Board of Directors.
5. If the investigation substantiates the report, the Organization will take appropriate corrective action, which may include disciplinary action, changes to internal controls, restitution, or referral to law enforcement or regulators.

7. Good-Faith Requirement

Anyone filing a report must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Reports made maliciously or without good-faith belief in the truth of the allegations are not protected by this policy and may themselves be the basis for disciplinary action.

8. Records

The Compliance Officer will maintain a log of all reports received under this policy, tracking receipt, investigation steps, findings, and corrective action, while preserving confidentiality as required. The log and underlying materials are retained per the Organization's Records Retention Policy.

9. Policy Distribution and Training

This policy will be distributed to all directors, officers, employees, and volunteers upon affiliation with the Organization and will be made publicly available on the Organization's website. The policy will be reviewed annually by the Board.