Effective Date: 04/01/2025

Last Updated: 04/01/2025

At Ariel, we are committed to fostering a culture of transparency, integrity, and accountability. We encourage employees, customers, suppliers, and other stakeholders to report unethical behavior, misconduct, or violations of laws and company policies without fear of retaliation.

1. Purpose

This policy outlines the rights and protections available to whistleblowers who report concerns in good faith. It ensures that all reports are taken seriously, investigated appropriately, and that whistleblowers are safeguarded against retaliation.

2. What Can Be Reported?

Whistleblowers are encouraged to report any of the following concerns:

–              Fraud, corruption, or financial misconduct

–              Bribery or conflicts of interest

–              Discrimination, harassment, or workplace abuse

–              Violations of health, safety, or environmental laws

–              Breach of company policies or legal regulations

–              Retaliation against employees who raise concerns

–              Any other unethical or illegal conduct

3. How to Report a Concern

Whistleblowers can report concerns through the following confidential channels:

1.         Online form

2.         Email: Info@arielgroup.com

3.         Phone: 781-761-9000

4.         Anonymous Submission: if you prefer to remain anonymous, you may submit your complaint here

Reports should include sufficient details to allow a thorough investigation. Anonymous reports will be accepted and investigated to the extent possible.

4. Protection Against Retaliation

No employee or stakeholder will face retaliation for making a report in good faith.  Retaliation, including dismissal, demotion, harassment, or any form of punishment against whistleblowers, is strictly prohibited.  Any individual found engaging in retaliation will face disciplinary action, up to and including termination.

5. Confidentiality

The identity of the whistleblower will remain confidential unless required by law.  Reports will be handled discreetly, and information will be shared only with those involved in the investigation.

6. Investigation Process

– Acknowledgment – A report will be acknowledged within 15 business days.

– Review & Investigation – The concern will be assessed, and an impartial investigation will be conducted.

– Resolution – If misconduct is confirmed, corrective action will be taken.

– Feedback – Where possible, the whistleblower will be informed of the outcome, respecting confidentiality limits.

7. False Reports

Deliberately false or malicious reports may result in disciplinary action. However, reports made in good faith, even if unproven, will not result in any penalties.

8. Policy Review

This policy will be reviewed periodically to ensure its effectiveness and compliance with applicable laws.