Effective Date: October 15, 2026 Version: 1.0 Applies to: All Company employees.
Article 1: Introduction and Scope
1.1 This document provides the protected channel through which an Employee reports misconduct, fraud, a violation of law, and a serious violation of Company policy, and states the protections that attach to such a report. A report under this document is not a support ticket, not an incident report, and not a grievance about a routine workplace disagreement; each of those has its own route, stated in Article 3, and no route removes the protection this document gives to a report of misconduct.
1.2 This document binds the Company as well as every Employee. The Company shall receive, investigate, and answer a report made under this document in accordance with Article 5, and shall not retaliate against a reporter, as Article 6 states.
1.3 If a provision of this document conflicts with the Terms of Use, this document controls for the subject it governs. If a provision conflicts with the terms of a program in which the Employee participates, the program terms control for that program. Help pages explain this document; they do not amend it.
Article 2: Definitions
2.1 The definitions in the Employee Code of Conduct are incorporated into this document by reference. This article defines only the additional terms used in this document, in alphabetical order.
2.2 Report: a communication made under Article 4 that alleges Misconduct, in the form that article states.
2.3 Misconduct: fraud; theft or misuse of funds, inventory, or data; falsification of a record; a violation of law; discrimination, harassment, or retaliation; a serious or deliberate violation of a Company policy; and conduct that creates a serious risk to the safety of a person or an animal and is concealed or left uncorrected after it is known.
2.4 Retaliation: an adverse act taken against an Employee because the Employee made a Report, participated in an investigation, or exercised a right this document protects, including termination, demotion, reduction of hours or pay, withdrawal of access or of a Grant, an adverse evaluation, and exclusion from duties or opportunities.
Article 3: What Is Reported Where
3.1 Misconduct is reported under this document. An Employee who is unsure whether a matter is Misconduct may report the matter under this document; a report made in good faith through the wrong route is transferred to the correct route by the person who receives it, and the transfer does not remove the protection of Article 6 where the matter reported is Misconduct.
3.2 An incident that involves harm or a risk of harm, without suspected Misconduct, is reported under the Employee Code of Conduct and answered under the Incident Response Policy. A question about pay, schedule, or a system is raised with the Manager or by support ticket. A concern about the Employee's own treatment that is not Misconduct is raised with the Manager or the Manager's manager. No person who receives a matter under another route shall treat the use of that route as a reason to refuse a Report of Misconduct.
Article 4: Making a Report
4.1 A Report is made in writing to legal@aapawz.com. The Report states, so far as the reporter knows: the conduct alleged; the persons involved; when and where the conduct occurred; the records, if any, that evidence it; and whether the conduct is continuing. A Report may attach records the reporter lawfully holds.
4.2 A Report may be made anonymously. An anonymous Report is investigated on the facts it states, to the extent those facts permit; anonymity limits the Company's ability to ask follow-up questions and to inform the reporter of the outcome, and does not prevent investigation. The Company shall not attempt to identify an anonymous reporter except where applicable law requires identification or the Report itself discloses the identity.
4.3 A Report may concern any person, including the reporter's Manager and any person senior to the reporter. Where a Report concerns the person who would ordinarily receive or investigate it, the Report is made to legal@aapawz.com under clause 4.1 and is investigated by a person the subject of the Report does not direct, in accordance with Article 5.
4.4 An Employee shall not be required to report Misconduct first to the Employee's Manager, to confront the person concerned, or to obtain any person's consent before making a Report. A Manager who receives an allegation of Misconduct directly shall transmit it to legal@aapawz.com promptly, shall not investigate it personally where the Manager is involved or is the subject, and shall not disclose the allegation beyond the transmission this clause requires.
4.5 A reporter acting in good faith is protected under Article 6 whether or not the allegation is substantiated. A Report made in good faith is a Report the reporter reasonably believes to be true on the information available to the reporter; a Report the reporter knows to be false is not made in good faith and is a violation of the Employee Code of Conduct.
Article 5: Receipt, Investigation, and Outcome
5.1 The Company shall acknowledge receipt of a Report that identifies the reporter, and shall assign the Report for investigation to a person who is not the subject of the Report and does not report to the subject of the Report. The investigation shall be prompt, shall be proportionate to the allegation, and shall gather the records and accounts that bear on the facts.
5.2 The contents of a Report and of an investigation are Confidential Information under the Confidentiality and Non-Disclosure Policy. Disclosure within the Company is limited to the persons whose duties require it for the investigation, the decision, and the remedy. The subject of a Report is informed of the allegation at the point the investigation requires it, except where earlier notice would compromise the investigation, a safety risk, or a legal obligation.
5.3 An Employee who is asked to participate in an investigation under this document shall cooperate, shall answer truthfully, shall preserve every record that relates to the matter, and shall not discuss the investigation with a person who has no duty in it. The subject of a Report may submit a written response and records, which the investigator shall consider before a determination is made.
5.4 On completion, the Company shall determine whether the allegation is substantiated, unsubstantiated, or unfounded, shall take the remedy the determination requires, including a measure under Article 8 against a person whose Misconduct is substantiated, and shall inform the reporter, where the reporter is identified, that the investigation is complete and whether the allegation was substantiated, without disclosing Personnel Information of another Employee beyond what the remedy requires. The record of the Report and the investigation is kept under the Record Keeping and Audit Policy.
Article 6: Non-Retaliation
6.1 The Company shall not retaliate against an Employee for making a Report in good faith, for participating in an investigation under this document, for refusing an instruction the Employee reasonably believes requires Misconduct, or for exercising a right this document or applicable law protects. No Manager shall take, direct, or permit Retaliation, and a Manager who learns of possible Retaliation shall report it to legal@aapawz.com promptly.
6.2 An Employee who believes the Employee has suffered Retaliation shall report the Retaliation in writing to legal@aapawz.com. Retaliation is investigated under Article 5 as a separate matter, by a person who did not make the decision complained of. Substantiated Retaliation is Misconduct and is enforced under Article 8.
6.3 Protection under this article does not prevent the Company from taking a measure against a reporting Employee for an independent, documented reason unconnected with the Report, including the Employee's own substantiated Misconduct. The Company shall record the reason for any such measure taken while a Report by that Employee, or an investigation involving that Employee, is open.
Article 7: Reports Outside the Company
7.1 Nothing in this document requires an Employee to report a matter to the Company before, or instead of, reporting it to a government agency, and nothing in this document prohibits, conditions, or requires notice of a report, charge, complaint, or communication to a government agency, or participation in an agency investigation or proceeding, or engagement in concerted activity protected by applicable law.
7.2 Nothing in this document, and nothing in the Confidentiality and Non-Disclosure Policy, prohibits an Employee from disclosing information to a government agency, or to an attorney for the purpose of reporting or investigating a suspected violation of law, as applicable law permits. An Employee is not required to inform the Company of such a disclosure.
Article 8: Liability
8.1 The Employee is responsible for the Employee's own conduct and shall bear the loss that the Employee's violation of this document causes, to the extent permitted by applicable law. Nothing in this document makes the Company responsible for a loss caused by an act taken in violation of this document or outside the scope of employment, and nothing in this document makes a reporter liable for a loss caused by the Misconduct the reporter reported.
8.2 To the fullest extent permitted by law, neither party is liable to the other for indirect, incidental, special, punitive, or consequential damages, or for lost profits, lost revenue, or loss of goodwill, arising out of or relating to this document, even if the party has been advised of the possibility of those damages. This clause does not limit a remedy that applicable law provides for Retaliation.
8.3 To the fullest extent permitted by law, the Company's total liability arising out of or relating to this document shall not exceed one hundred dollars ($100). This clause does not limit (a) wages, commissions, benefits, or other compensation owed under applicable law or a written agreement; (b) a remedy for Retaliation that applicable law provides and does not permit to be limited; (c) indemnification obligations under this document; (d) liability for fraud or willful misconduct; or (e) liability that cannot be limited under applicable law.
8.4 The parties agree that this article allocates risk between them, that it is an essential part of the basis of their bargain, and that it applies even if a limited remedy fails of its essential purpose.
Article 9: Indemnification
9.1 The Company shall indemnify, defend, and hold harmless the Employee from and against a claim, loss, liability, judgment, settlement, cost, and expense (including reasonable attorneys' fees) brought by a third party and arising out of an act the Employee took within the scope of employment and in compliance with this document and applicable law, including the making of a Report in good faith and participation in an investigation.
9.2 The Company does not indemnify an Employee for the Employee's own unlawful acts. No indemnification is owed under this article for a claim arising out of (a) the Employee's willful misconduct or fraud, including a Report the Employee knows to be false; (b) an act outside the scope of employment; or (c) an act taken in violation of this document.
9.3 The Employee shall indemnify, defend, and hold harmless the Company and its members, managers, employees, and agents from and against every claim, loss, liability, judgment, settlement, cost, and expense (including reasonable attorneys' fees) arising out of (a) the Employee's breach of this document; (b) the Employee's violation of any law or of the rights of any person; and (c) an act outside the scope of employment.
9.4 The party seeking indemnification shall give prompt written notice of a claim under this article. The indemnifying party shall control the defense with counsel reasonably acceptable to the other party; the indemnified party may participate at its own expense. The indemnifying party shall not settle a claim in a manner that imposes an obligation on the other party, or that does not release the other party fully, without the other party's prior written consent. This article survives the end of employment.
Article 10: Enforcement and Appeals
10.1 The Company may investigate any suspected violation of this document, including a suspected failure to transmit a Report under Article 4 and suspected Retaliation under Article 6. The Employee shall cooperate with an investigation and shall produce the records this document requires the Employee to keep.
10.2 If the Company determines that the Employee has violated this document, the Company shall give written notice stating the provision violated and the facts relied on, except where notice would compromise an investigation of fraud, a safety risk, or a legal obligation. The Employee may submit a written response within ten (10) business days, and the person deciding the matter shall consider the response before a measure is imposed. Where a violation is capable of cure, the Employee has ten (10) business days from notice to cure it and to confirm the cure in writing; no cure period applies to Retaliation, fraud, or a violation that cannot be cured.
10.3 If a violation is established, the Company may, proportionate to the violation: (a) issue a written warning; (b) require retraining; (c) restrict or withdraw access or a Grant; (d) place the Employee on a written improvement plan; (e) suspend the Employee's employment; (f) terminate the Employee's employment; and (g) exercise any other right or remedy available at law. Retaliation against a reporter, and the suppression or mishandling of a Report by a Manager, are serious violations for the purposes of this article.
10.4 The Employee may appeal a measure under this article in writing to legal@aapawz.com within thirty (30) days of the measure, stating the grounds and attaching the records relied on. The appeal is decided by a person who did not make the original decision, and the Company's decision on appeal is final. A measure remains in effect during an appeal unless the Company directs otherwise in writing.
10.5 No measure under this article may be imposed in retaliation for a Report made in good faith or for the exercise of a right protected by applicable law. The Company's delay in acting on a violation is not a waiver of the violation or of any later violation of the same kind.
Article 11: Term and Termination
11.1 This document applies from the commencement of employment until the employment ends for any reason. The protection of Article 6 attaches to a Report when the Report is made and does not end with the employment: Retaliation after separation, including an adverse reference given because of a Report, is prohibited by this document.
11.2 On the end of employment, Articles 6, 7, 8, 9, 10 (for measures taken before the employment ended), 12, and 13 survive. A Report made before separation is investigated to completion under Article 5. The end of employment and of access is governed by the Termination and Offboarding Policy.
Article 12: Dispute Resolution
12.1 Any dispute arising out of or relating to this document, or to the relationship it governs, is governed by the Dispute Resolution Policy, which is incorporated into this document by reference.
12.2 Nothing in this document, including this article, limits an Employee's right to file a charge or complaint with a government agency, to participate in a proceeding of a government agency, or to engage in concerted activity protected by applicable law, and no provision of this document requires the Employee to give the Company notice of, or to obtain the Company's consent to, the exercise of such a right.
Article 13: General Provisions
13.1 The Company may amend this document by posting the amended document in the Document Center and giving notice to the Employee at the email address in the Employee's employment record. An amendment that materially increases the Employee's obligations takes effect thirty (30) days after notice; other amendments take effect on posting. No amendment removes the protection of Article 6 from a Report made before the amendment takes effect.
13.2 Legal notices under this document, and Reports under Article 4, shall be sent to legal@aapawz.com; operational notices and all other communications shall be sent to support@aapawz.com. A notice to the Company is effective when the Company acknowledges receipt or, for email, one business day after sending, whichever is earlier. Notices to the Employee are effective when sent to the email address in the Employee's employment record or posted in the employee portal, whichever occurs first. The Employee shall keep that email address current. Notices under the DMCA and Copyright Policy are given as provided in that policy, to the designated agent at legal@aapawz.com.
13.3 This document is governed by the laws of the State of Tennessee, without regard to its conflict-of-laws rules. Subject to the Dispute Resolution Policy, any proceeding arising out of this document shall be brought in the state or federal courts located in Shelby County, Tennessee, and the parties consent to personal jurisdiction there.
13.4 If any provision of this document is held unenforceable, the provision shall be enforced to the fullest extent permitted, and the remaining provisions continue in full effect.
13.5 This document, together with the documents it incorporates by reference, is the entire agreement between the Company and the Employee for the subject it governs and supersedes every prior statement or agreement on that subject. This clause does not supersede an offer letter or a written employment agreement signed by the Company.
13.6 The Employee shall not assign this document or any right or obligation under it, and an assignment without the Company's prior written consent is void. The Company may assign this document to an affiliate or in connection with a sale of all or part of its business, on notice to the Employee. A waiver of any provision of this document is effective only in writing and only for the instance stated; no waiver is a waiver of any other provision or instance.
13.7 Headings are for convenience only. "Including" means "including without limitation." This document shall not be construed against a party on the ground that the party prepared this document. The English-language text controls over any translation.
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