Any employee of Moser&Correia Lda. may submit a good faith complaint regarding accounting, auditing, purchasing and sale practices, environmental, human resources or health and safety matters to the management of the Company without fear of dismissal or retaliation of any kind. The Company is committed to achieving compliance with all applicable laws and regulations, accounting standards, accounting controls and audit practices. The Company's Audit Committee, Vice President of Business Compliance and corporate counsel will oversee treatment of employee concerns in these areas.
In order to facilitate the reporting of employee complaints, the Company's Audit Committee has established the following procedures for (1) the receipt, retention and treatment of complaints regarding accounting, internal accounting controls or auditing matters ("Accounting Matters") or other matters ("Other Matters", and in combination with Accounting Matters "Matters") and (2) the confidential, anonymous submission by employees of concerns regarding questionable accounting, auditing or other matters.
Receipt of Employee Complaints
Employees with concerns regarding any Matters may report their concerns to the Vice President of Business Compliance of the Company. Employees may forward complaints on a confidential or anonymous basis to the Vice President of Business Compliance e-mail or regular mail:
Scope of Matters Covered by These Procedures
The procedures apply to employee complaints relating to any questionable Accounting Matters, including, without limitation, the following:
• Fraud or deliberate error in the preparation, evaluation, review or audit of any financial statement;
• Fraud or deliberate error in the recording and maintaining of financial records;
• Deficiencies in or noncompliance with internal accounting controls;
• Misrepresentation or false statement to or by a senior officer or accountant regarding a matter contained in the financial records, financial reports or audit reports; or
• Deviation from full and fair reporting of the Company’s financial condition.
The procedures also apply to employee complaints relating to any Other Matters, including, without limitation, the following:
• Purchase of merchandise and selling practices
• Environmental matters;
• Issues related to health and safety;
• Human resource matters; or
• Any other concerns or issues related to any aspect of our company.
Treatment of Complaints
Upon receipt of a complaint, the Vice President of Business Compliance will determine whether the complaint pertains to Accounting Matters or Other Matters.
Complaints relating to Accounting Matters will be reviewed under Audit Committee direction and oversight by Odimo’s corporate counsel, or such other persons as the Audit Committee determines to be appropriate.
Complaints relating to Other Matters will be reviewed under the direction and oversight of the Vice President of Business Compliance with input and direction from the Company’s counsel or such other persons as the Vice President of Business Compliance determines to be appropriate.
Prompt and appropriate corrective action will be taken when and as warranted in the judgment of the Audit Committee or corporate counsel. Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review.
The Company will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee in the terms and conditions of employment based upon any lawful actions of such employee with respect to good faith reporting of complaints regarding Accounting Matters.
Reporting and Retention of Complaints and Investigations
The Vice President of Business Compliance will maintain a log of all complaints, tracking their receipt, investigation and resolution and shall prepare a periodic summary report thereof for the Audit Committee. Copies of complaints and such log will be maintained in accordance with the Company’s document retention policy.