. Procedure for Receiving Complaints
Employees with concerns or complaints regarding matters covered by the Audit Committee Whistleblower Procedure may report such concerns or complaints through the Company's Ethics hotline, e-mail, fax or regular mail. Concerns and complaints received through these means shall be forwarded to the Vice President –Internal Audit.


The General Counsel shall notify the Vice President – Internal Audit of any report submitted to him or her by a Company attorney pursuant to the SEC rules of attorney conduct that includes evidence of a material violation of state or federal securities laws, a material breach of fiduciary duty or similar material violation of any federal or state law ("Attorney Reports").

II. Scope of Matters Covered by these Procedures
(i) fraud or deliberate error in the preparation, evaluation, review or audit of any financial statement of the Company;

(ii) fraud or deliberate error in the recording and maintaining of financial records of the Company;

(iii) deficiencies in noncompliance with Companys internal accounting controls;

(iv) 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 of the company;

(v) deviation from full and fair reporting of the Companys financial condition;

(vi) mail fraud, wire fraud, bank fraud, securities fraud, violation of any SEC rule or regulation or violation of any federal law relating to fraud against shareholders; and,

(vii) Attorney Reports.

III. Procedure for Handling Complaints

  1. Receipt of a Complaint
    Upon receipt of a complaint, the Vice President – Internal Audit will forward a copy of the complaint to the Aon Law Division and when possible, acknowledge receipt of the complaint to the sender. (Considering that most complaints will be anonymous, it is understood that such acknowledgement may not be possible in most cases.) The Vice President Internal Audit and Law Division will verify that the complaint actually pertains to a matter covered by these procedures and develop a recommended strategy for the investigation of the complaint.
  2. Audit Committee Oversight
    The Vice President – Internal Audit will promptly report all complaints relating to material matters covered by these procedures and the recommended strategy for investigating the complaint to the Chairman of the Audit Committee (Chairman). The Chairman shall provide direction and oversight to the Vice President Internal Audit, General Counsel or such other person as the Chairman shall deem appropriate to conduct the investigation.
  3. Confidentiality
    Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review.
  4. Corrective Action
    Prompt and appropriate corrective action will be taken as warranted in the judgment of the Audit Committee.
  5. Procedure Prohibiting Retaliation
    In compliance with Section 806 of the Sarbanes-Oxley Act of 2002, the Company will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee in the terms and conditions of his/her employment based upon the lawful action of any such employee with respect to good faith reporting of a matter covered by these procedures.

IV. Reporting and Retention of Complaints and Investigations
The Vice President – Internal Audit will maintain records of all complaints covered by these procedures, tracking their receipt, investigation and resolution and shall prepare a periodic report to the Audit Committee until the matter has been resolved to the satisfaction of the Audit Committee. Copies of all complaints and investigation records will be maintained in accordance with the Company's document retention policy.