Policy Overview
IZEA Worldwide, Inc., including all its subsidiaries and affiliates (“IZEA”), is dedicated to upholding the highest standards of integrity, transparency, and accountability, and therefore, we encourage any parties with relevant information to report any unlawful conduct (such as harassment, discrimination, bribery, fraud, theft, etc.), financial misconduct, safety issues, environmental hazards, or potential violations of our codes of conduct, policies, standards, or applicable laws to our General Counsel, the Audit Committee, and/or, as appropriate, to our Board of Directors, senior management, or financial advisers to ensure that appropriate measures can be taken in accordance with this Policy.
A “Whistleblower” means a person who makes a report in accordance with this Policy. Any person who has a professional relationship with IZEA, whether this relation is in progress, terminated or has yet to begin, can be considered a Whistleblower, including:
- Employees, former employees or prospective employees (including part-time, fixed term interim, interns, job applicants, volunteers etc.);
- Shareholders and persons belonging to the administrative, management or a supervisory body of an undertaking, including non-executive members; and
- IZEA’s business partners (consultants, contractors, freelancers, agents, agency workers, shareholders, board members, distributors etc.).
What Should Be Reported by a Whistleblower?
You can report any concerns of suspected misconduct, breach or violation involving IZEA, relating to:
- local laws or regulations in the countries where IZEA has a presence or is doing business;
- wrongdoing and dangers in relation to IZEA’s activities; and
- IZEA’s Code of Conduct, Ethics, Business Partner Statement of Ethics, or any other IZEA policies or industry standards.
This includes, for example:
- bribery, money laundering, fraud, corruption or other criminal activity;
- tax evasion or other financial misconduct;
- violence, threats, bullying, harassment, discrimination, substance abuse;
- abuse of IZEA’s property (including intellectual property and confidential information);
- any hinderance or obstruction to, or attempts to hinder or obstruct a report,
- any attempts to retaliate or retaliation against a Whistleblower or person assisting a Whistleblower or with an investigation; and
- the deliberate concealment of any of the above matters.
Any employee who believes that they may have been personally involved in misconduct, or a policy violation is still expected to report such incidents. Self-reporting will be considered when deciding whether or what disciplinary action is appropriate.
It is important that all reports and claims should be made in good faith. Malicious reports, reports you know to be false, reports entirely based on rumors, or reports not concerning IZEA should not be reported under this Policy.
Whistleblower Process
All reports should include as much detail as possible, and should be made through the following channels:
- If you are an IZEA employee, consultant, contractor, or freelancer:
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- Your manager; or
- IZEA’s General Counsel, if you are uncomfortable speaking with your manager for any reason.
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- If you are a shareholder, vendor, business party, and/or any other non-IZEA affiliated party:
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- IZEA’s General Counsel
- IZEA’s Audit Committee Chair;
- IZEA’s Board of Directors, senior management, or auditors, if appropriate; and/or
- IZEA’s Whistleblower Hotline or Email address, as provided in the Contact Details at the end of this policy.
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Whistleblowers may also have the right to report concerns directly to regulatory authorities, such as the Securities and Exchange Commission (SEC), and may be eligible for protections and rewards under these laws.
Confidentiality
IZEA will make every effort keep your identity, the reported facts and the identity of the persons covered by the report, confidential. Your identity will not be disclosed beyond the authorized to receive or follow up on reports without your consent, unless we are required to do so by law or by a judicial authority.
Please also note that you can report your concerns anonymously if you choose, and all such reports will be investigated to the fullest extent possible, based on the information provided.
Retaliation is Prohibited
IZEA will ensure that those who make a report in good faith are not retaliated against. This protection also covers people who help the Whistleblower with the report, anyone connected to the person reporting who might face backlash at work, witnesses or anyone helping with an investigation, and companies that the reporting person owns, works for, or is linked to through work. Any party that hinders (or attempt to hinder), threatens, penalizes or retaliate against a Whistleblower in any way, may be subject to disciplinary action. Prohibited retaliation includes:
- any negative impact on your contractual relationship with IZEA
- blacklisting in a sector or industry-wide informal or formal agreement; or
- discrimination, disadvantageous or unfair treatment.
Additionally for IZEA employees, prohibited retaliation also includes:
- suspension, lay-off, dismissal or equivalent measures;
- demotion or withholding of promotion;
- reduction in wages, change in working hours;
- withholding of training; or
- negative performance assessment or employment reference.
If you believe that you have suffered any retaliation as the result of a disclosure, you should immediately contact IZEA’s General Counsel.
Contact Details
For further advice relating to the Policy or if you have concerns relating to a potential breach of the Policy, please contact the IZEA’s General Counsel, Sandra Carbone, at Sandra.Carbone@izea.com.
