Corporate Governance - Governance, Risk, and Compliance Topic for Oracle Applications - page 74

(B) the confidential, anonymous submission by employees of the issuer of concerns
regarding questionable accounting or auditing matters."

Section 806 states:

"No company with a class of securities registered under section 12 of the Securities
Exchange Act may discharge, demote, suspend, threaten, harass, or in any
other manner discriminate against an employee in the terms and conditions of
employment because of any lawful act done by the employee to provide information
regarding any conduct which the employee reasonably believes constitutes a
violation of the Securities and Exchange Commission."

There are a number of ways to support Whistle-blower reporting. Some companies
choose to outsource to a third party. Some have a hotline. You may configure Oracle
Survey to allow for anonymous submission of a survey to capture whistle-blower
issue. You can configure the issue logging in GRC Manager to serve as the log of
whistle-blower issues. However, we have chosen to explain a little more about the
set up of the iService product and how it might be configured to provide whistle-
blower incidents with anonymous creation, the ability to track progress for the
reporter and the board. It is in its nature, intended to be able to be used by people
who are not logged in, and it is intended to give them a number by which they can
track their problem.

The following diagram shows the process for processing whistle-blower complaints:

1 2 4 3

Issue Tracking
Number

Investigate Grievance

Enter Grievance Alert Audit Commitee

5

Update Grievance

D1 Whistleblower Grievance

6
Review Grievance
Display