Business Ethics and Compliance Policy
A. General Policy and Procedures
The reputation of Innosoft Corporation (“Innosoft” or the “Company”) is based on the conduct, integrity and abilities of our Personnel. The Company expects all of its Personnel to share its commitment to high ethical and legal standards and to avoid any activities that could involve the Company or its Personnel in any real or perceived unethical, improper, or unlawful act. As used in this policy, the terms “colleague” and “personnel” shall refer to all Resources(including all employees and consultants of the Company), as well as the officers and, as applicable, directors of the Company, unless otherwise indicated.
Careful review of this policy will provide Personnel with a better understanding of the Company’s expectations and of Personnel’ own obligations. Compliance with this policy is mandatory and it is the duty of all Personnel to familiarize themselves with the policy as well as the legal standards and policies specifically applicable to their assigned duties and to conduct themselves accordingly. Compliance with this policy will be a factor in each personnel’s performance review. Violations of this policy are subject to discipline, up to and including termination of services.
B. Additional Requirements
The policy is not intended to be an exclusive set of guidelines or requirements governing the conduct of Personnel. The Company has adopted and may amend or adopt other corporate policies, procedures, Personnel manuals or employee handbooks that also proscribe or specify conduct. Moreover, no single policy or set of policies can ever be totally comprehensive or serve as a substitute for the good judgment, common sense and proper, ethical and legal conduct we expect of all Personnel.
This policy does, however, supersede the Code of Business Ethics and Conduct section of the Handbook. It also reinforces and adds to the requirements for conduct by Personnel set forth in other Innosoft policies. To the extent that anything in this policy is in conflict with the provisions of these other sources, the provisions of this policy will govern. Collectively, this and other policies of conduct may be referred to as the policy or code of conduct at Innosoft.
C. Corporate Compliance Officer
Innosoft’s Executive Vice President, Business Development is designated as the Corporate Compliance Officer. In this position, he or she has the ultimate responsibility for overseeing compliance with all applicable laws and policy.
The designation of a Corporate Compliance Officer in no way diminishes the responsibilities of all Personnel to comply with all applicable laws and all Company policies, nor does it diminish every manager’s responsibility to oversee compliance by the Personnel under his or her supervision with all applicable laws and all Company policies.
D. Giving Required Notification/Disclosure
Any notification or disclosure called for in this policy must be given by email to Contracts@Innosoft.com. Such notification or disclosure must include the purpose of the notification or disclosure and include such additional information as the Corporate Compliance Officer shall request, including information called for in any form or template posted by the Corporate Compliance Officer or Corporate Human Resources for purposes of providing notification or disclosure called for in this policy.
Anyone with questions or doubts about the application of the policy or who is aware of or suspects a violation of the policy should consult with the Corporate Compliance Officer or should follow the procedures provided in Section XIII or in accordance with the provisions of the Company’s Open Door Policy on Reporting Complaints.
II. Compliance with Laws and Ethical Business Conduct
Recognition of the public interest is a permanent commitment of the Company in the conduct of its business. The activities of the Company must always be in compliance with all applicable laws, statutes, and regulations.
Personnel occupy positions of trust and confidence. In discharging their responsibilities, each Personnel has a duty to serve the Company, in good faith, in a manner that he or she reasonably believes to be in the best interests of the Company and with such care as an ordinary prudent person in a like position would use under similar circumstances. Personnel also have duties of candor, care and loyalty to the Company. These duties include, but are not limited to, the duty to make a reasonable inquiry where the circumstances require such inquiry; the duty to disclose all material information relevant to corporate decisions from which that person may derive, directly or indirectly, a personal or other benefit; the duty to deal openly with and make full disclosure to the Company; the duty to avoid and disclose any activities which could create, or appear to create, a conflict with the interests of the Company, as discussed in Section III; the duty not to exploit one’s positions with the Company in doing severe damage to the Company and its reputation; and the duty to act with integrity, fidelity, and high standards of conduct.
III. Conflicts of Interest
Except as provided elsewhere in this policy, or to the extent a right to do so is protected by law, Personnel must avoid providing services or business activities, including bias in resource recruitment, that interfere with their duties to the Company, divide their loyalty, or create or appear to create a conflict of interest, unless such services or activities are fully disclosed to the Company and approved by written consent.
It is not possible to provide a precise, comprehensive definition of a conflict of interest. However, one factor that is common to all conflict of interest situations is the possibility that a person’s actions or decisions may be affected or have the appearance of being affected because of an actual or potential divergence between the interests of the Company and some other interest, including that person’s own personal interests. Conflicts of interest also arise when a colleague, officer or director, or a member of his or her family, receives improper personal benefits as a result of his or her position in the Company. A particular activity or situation may be found to involve a conflict of interest even though it does not result in any financial loss to the Company and irrespective of the motivations of the person involved. Other factors to be considered in determining whether a conflict of interest exists include:
- whether it may interfere with the personnel’s job performance, responsibilities or morale;
- whether the personnel has access to confidential information;
- whether it may interfere with the job performance, responsibilities or morale of others within the organization;
- any potential adverse or beneficial impact on our business;
- any potential adverse or beneficial impact on our relationships with our customers or Vendors or other service providers;
- whether it would enhance or support a competitor’s position;
- the extent to which it would result in financial or other benefit (direct or indirect) to the personnel;
- the extent to which it would result in financial or other benefit (direct or indirect) to one of our customers, Vendors or other service providers; and
- the extent to which it would appear improper to an outside observer.
The facts of each case will determine whether the interest in question involves an actual or potential conflict. A person shall promptly report any situation or transaction involving an actual or potential conflict of interest to his or her supervisor, Corporate HR and the Corporate Compliance Officer.
B. Business or Investment Opportunities
If Personnel learn of a business, proposal or recruitment opportunity through the use of corporate property or information or their position at the Company, such as from a competitor or actual or potential client, Vendor or business associate of the Company, they may not participate in the opportunity without the prior written approval of the Corporate Compliance Officer. Such an opportunity should be considered to promulgate interest of the Company.
Just as Personnel owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises, Personnel are also prohibited from (i) using Company property, information, or position for personal gain; and (ii) directly or indirectly competing with the Company in any capacity, including, as a contractor, employee, director, officer, partner, or sole proprietor of a competing concern.
C. Interest in Companies Transacting Business with Innosoft
It is the policy of the Company to select Vendors and others on the basis of merit, without favoritism. As such, this policy requires that Personnel avoid any relationship or activity that may directly or indirectly impair their independence or judgment. The Company recognizes that from time to time it may transact business with a company in which a colleague, a colleague’s spouse or children (“Immediate Family”) have an interest or are employed. The Company also recognizes, however, that this could present a conflict of interest, or the appearance of one, if the colleague did not disclose the relationship or if he or she participated in the approval process. Therefore, whenever the Company does or considers doing business with a company, or independent contractor, in which a colleague or member of a colleague’s Immediate Family is employed or has a material financial or other interest, the colleague must: (i) disclose the interest to his or her supervisor, and (ii) refrain from participating in the review process. The actions listed here are in addition to any additional actions required by the Company’s Related-Person Transaction Policy.
A conflict of interest may also arise where a colleague or a member of his or her Immediate Family supports a company that does business or competes with the Company. If a colleague or a member of his or her Immediate Family is considering supporting a company that does business, is being considered to do business with, or competes with the Company, the colleague should disclose such activity in advance to his or her supervisor and seek approval for it. If such approval is obtained, the colleague shall comply with any conditions of the approval and shall not participate in any decision regarding such business activity.
The receipt of gifts, loans, favors, or other gratuities from a company that is doing business with Innosoft is further addressed in Section V.
D. Employment of Relatives
To avoid conflicts of interest and promote stability and goodwill in the workplace, the Company does not ordinarily hire or transfer relatives into positions where they supervise or are supervised by another close family member. The Company also generally avoids placing them in positions where they work with or have access to sensitive information about family members. The same general considerations apply if two Personnel marry or become involved in a domestic partner relationship. If a supervisory, security, morale, safety, or other conflict results from the relationship, the Company reserves the right to use its full discretion to address these concerns. One of the Personnel may be transferred—or, if necessary, discharged from services—to resolve the situation, for example. By relatives, the Company means Immediate Family and parents, legal guardians, siblings, grandparents, grandchildren, and current in-laws, as well as significant others and domestic partners. There may be other considerations or restrictions based on job requirements and situations specific to the Company.
E. Outside Employment
The Company recognizes and encourages the participation of Personnel in religious, charitable, educational, and civic activities.
The Company discourages for-profit employment by Personnel in other business ventures, unless it is clear that such employment poses no potential conflict with employment by the Company. If a colleague wishes to engage in activities as an employee, general partner, consultant, agent or trustee of a business or a for profit organization, the colleague must disclose the proposed relationship to the Corporate Compliance Officer and seek prior approval. Such approval may be granted if the proposed employment or activities do not interfere with the performance of the colleague’s duties and do not involve a conflict of interest with the Company. Should a colleague be approved for outside employment, the colleague should not engage in solicitation of customers, customers’ Personnel or internal Personnel of the Company.
IV. Fair Dealing
The Company depends on its reputation for quality, service and integrity. The way we deal with our customers, competitors, and Vendors molds our reputation, builds long-term trust and ultimately determines our success. Personnel should endeavor to deal fairly with the Company’s customers, Vendors, competitors and each other. Personnel must never take unfair advantage of others through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair dealing practice. If information is obtained by mistake that may constitute a trade secret or other confidential information of another business, or if a colleague has any questions about the legality of proposed information gathering, he or she must consult his or her supervisor or the Corporate Compliance Officer. However, Personnel should remember that their first duty in this regard is to the Company, and accordingly, any disclosure of any confidential information, including pricing or negotiating information, without the prior approval of the Corporate Compliance Officer shall be subject to discipline, up to and including termination of service, and such other legal remedies as may be available to the Company.
Antitrust laws are designed to protect competitive processes. These laws are based on the premise that the public interest is best served by vigorous competition and will suffer from illegal agreements or collusion among competitors. Antitrust laws generally prohibit:
- agreements, formal or informal, with competitors that harm competition or customers, including price fixing and allocations of customers, or contracts;
- agreements, formal or informal, that establish or fix the price at which a customer may resell a product; and
- the acquisition or maintenance of a monopoly or attempted monopoly through anti- competitive conduct.
Certain kinds of information, such as pricing, should not be exchanged with competitors, regardless of how innocent or casual the exchange may be and regardless of the setting, whether business or social.
Antitrust laws impose severe penalties for certain types of violations, including criminal penalties and potential fines and damages of millions of dollars, which may be tripled under certain circumstances. Understanding the requirements of antitrust and unfair competition laws of the various jurisdictions where we do business can be difficult, and Personnel are urged to seek assistance from their supervisors or the Corporate Compliance Officer when facing a question relating to these laws.
V. Receipt of Gifts, Gift Cards, Entertainment, Favors or Other Gratuities
Innosoft’s policy is that the opportunity to do business with Innosoft cannot be bought by any third party by giving gifts to Innosoft Personnel who might be in a position to influence approval of a customer’s or vendor’s business. To enforce this policy, no colleague is allowed to accept any gifts, gift cards, entertainment, favors or other gratuities from any person or organization if such a gift would influence decision-making at Innosoft.
To avoid even the appearance of impropriety, the following restrictions apply to Personnel and to their Immediate Families with respect to favors from outside sources that do business, or are seeking to do business, with Innosoft:
- No one may solicit or accept cash or cash equivalents.
- No one may solicit gift cards or gift certificates, but Personnel may accept unsolicited gift cards or gift certificates totaling less than $50 per calendar year from any one source, and no more than $200 per calendar year from all sources. Any gift cards or gift certificates received by a colleague must be promptly reported to the Corporate Compliance Officer (via Contracts@Innosoft.com) and any gift cards or gift certificates received over the limit will either be required to be promptly returned or contributed to a charity approved by the Corporate Compliance Officer.
- No one may solicit or accept any gift with a value of $50 or more or total gifts from one source with value totaling more than $200 per calendar year, unless such gifts are approved by a Company executive and reported to the Corporate Compliance Officer.
- No one may solicit or accept any entertainment, paid trip or guest accommodations with a value of more than $50 per calendar year from any one source nor totaling more than $200 per calendar year from all sources, unless reported to and approved by the Corporate Compliance Officer. This does not prohibit, however, paid trips or guest accommodations in connection with proper Company business approved by a manager and the Corporate Compliance Officer.
- No one may solicit or accept any discounts not available to the general public or other substantial remuneration or favor for his or her benefit, unless approved by and reported to the Corporate Compliance Officer. This does not prohibit, however, Personnel or members of their Immediate Families from obtaining discounts on purchases or provided in the ordinary course of business, or other services (on the same terms as are generally available to the public) from vendors, Service providers, banks or any other organizations that have relationships with the Company
Exceptions to these policies may be made only with the written approval of the Corporate Compliance Officer.
VI. Use of the Company Funds or Other Resources
The Company’s funds, assets, services of Company Personnel and other resources of the Company (collectively, “Resources”) are to be utilized solely for the benefit of the Company and only for legitimate business purposes. The Company’s policy is to prohibit the use of such Resources for any purpose other than for the benefit of the Company, unless otherwise approved in advance in accordance with the prescribed procedures, and to prohibit any questionable or unethical disposition or use thereof. Personnel should protect the Company’s assets and ensure their efficient use.
A colleague who has access to Company funds must follow the prescribed procedures for recording, handling and protecting money as detailed in the Company’s manuals or other written policy documentation. Where a colleague’s position requires spending of Company funds or incurring any personal expenses to be later reimbursed by the Company, it is the individual’s responsibility to use good judgment on the Company’s behalf and to ensure that good value is received for every expenditure, and to follow all Company policies and procedures relating to authorization and approval for such expenditures. Company funds should only be used for Company purposes and must not be used for personal benefit.
A. Personal Use of the Company Funds or Other Resources
Without the prior permission of the Company as set forth herein or in a Company manual or written policy, no colleague is permitted to appropriate or authorize any other person or entity to appropriate for their use any Company Resources. Misappropriation of any Company Resource is theft and, in addition to subjecting a person to possible criminal and civil penalties, may result in immediate termination of services or other disciplinary action.
B. Payments and Gifts
The Company’s Resources must not be directly or indirectly used for any unlawful or unethical purpose.
1. Payments and Gifts to Government Officials
No colleague may authorize or participate in any payment or gift of any of the Company’s Resources to any governmental agency (other than payments in the ordinary course of business) or official for any purpose unless approved by the Corporate Compliance Officer in writing in advance. It is never permissible to make any payment or gift for the purpose of inducing or influencing the recipient or another person to improperly grant special consideration to or forego any claim against the Company (except as part of a proper settlement agreement approved by the Legal Department).
The Company’s Personnel are expected to comply with the applicable laws including laws prohibiting bribery, corruption or the conduct of business with specified individuals, companies. The fact that, certain laws are not enforced or that violation of those laws is not subject to public criticism will not be accepted as an excuse for noncompliance. We expect Personnel to comply with U.S. laws, rules and regulations governing the conduct of business by its citizens and corporations. Personnel should seek assistance before taking any action, including giving any verbal assurances that might be regulated by laws if there is any question as to whether an activity is restricted or prohibited.
2. Payments and Gifts to Others
Personnel should avoid all circumstances in which providing a gift or entertainment could present or create the appearance of a conflict of interest or improper, unethical or illegal conduct. To avoid such circumstances, Personnel may give incidental gifts, favors and entertainment of nominal value to others on behalf of the Company only if they are consistent with accepted business practice, are of sufficiently limited value and in a form that will not be construed as an improper payment.
No gift or entertainment is permitted if it violates any applicable laws or ethical standards. Gifts, favors or entertainment of less than substantial value will generally be permitted, although the facts and circumstances of each case need to be considered and, if in doubt, approval should be sought from the Corporate Compliance Officer. In all cases involving gifts, entertainment or favors of substantial value, approval of the Corporate Compliance Officer must be obtained in advance.
VII. Political Contributions
There are three basic tenets of the Company’s policy with respect to political contributions: First, the Company unequivocally forbids the illegal use of Company Resources for the support of political parties or political candidates for any office (federal, state or local) in the United States or any foreign country. Second, the Company forbids pressure, direct or implied, that infringes upon the right of Personnel to decide whether, to whom, and in what amount they will make a political contribution or render services to individual candidates or political committees where permitted by applicable laws. Personnel are free, and indeed are encouraged, to endorse, advocate, contribute to, or otherwise support any political party, candidate or cause they may choose. Third, any permitted Company political contributions must be approved by the Corporate Compliance Officer.
VIII. Corporate Records
A. Record Keeping
It is Company policy to make full, fair, accurate, timely and understandable disclosure in compliance with all applicable laws and regulations in all reports and documents and in all other public communications made by the Company. Accurate and complete record-keeping is essential to the corporate well-being of the Company and to enable it to comply with legal and regulatory requirements, to manage the affairs of the Company and to provide the best possible service to its customers. The Company adheres to a strict policy of maintaining complete and accurate books and records including, but not limited to, memoranda, expense reports, accounts, contracts, financial reports and other business or corporate records. The Company’s books and records must reflect, in an accurate and timely manner, all business transactions. Undisclosed or unrecorded funds, other assets, or liabilities are not permitted. All persons are expected and required to prepare, preserve and produce all books and records in accordance with this policy, and with the separately published record retention policy referenced below in subsection B. In order to protect the privacy of Company officers and Personnel and comply with federal and state law, Personnel must ensure that all records containing medical or personal data about Personnel are kept confidential and only disclosed as authorized. Furthermore, medical information about officers and Personnel and all documents used to verify work eligibility, such as I-9 Forms, should be kept in files which are separate from those that contain general Personnel information.
B. Record Retention
The Company has specific requirements for retaining various categories of records generated by the Company as set forth in the Company’s Business Record Retention Policy. Accordingly, the Company must retain all records that have any bearing on threatened or pending litigation, investigations, or administrative proceedings.
Officers and Personnel who are notified of the existence of a subpoena or have reason to believe that a government investigation is imminent or that legal proceedings may be instituted must retain all potentially relevant records in their possession, custody, or control, including papers, computer disks, and tapes, until they have been notified otherwise by the Company Executive Management. Also, managers must ensure that Personnel under their supervision retain all such records in their possession, custody, or control. (Subpoena obligations are discussed further in Section X below.)
IX. Approval of Expenses
No payment by or on behalf of the Company will be approved, made or reimbursed if any part of the payment is to be used for a purpose not in compliance with the Company’s Personnel Travel & Expense Policy, available on the HR Portal. All proper and valid requests for reimbursement by Personnel must be made in accordance with this policy and with other procedures the Company may from time to time adopt.
X. Media, Regulatory, Legal and Other Inquiries
As a general matter, no Personnel are permitted to disclose to any non-Innosoft Personnel any non-public information about the Company except in accordance with this policy or other applicable Company policies.
B. Conduct Regarding Media Inquiries
When a determination is made in accordance with the procedures set forth herein to respond to media inquiries, it is the Company’s policy to fully and fairly convey accurate information to members of the news media. However, it is also the Company’s policy to protect and safeguard its confidential information. Therefore, in order to preserve and maintain the integrity of communications, no colleague, other than the Chief Executive Officer and those designated from time to time as spokespersons by the Company may discuss matters involving the Company or its affiliates, Personnel, creditors, consultants, counsel, accountants and agents with any member of the news media.
It is imperative that all Personnel follow this policy and not respond to media inquiries unless authorized in accordance with this policy even when the question appears to relate to objective facts within the knowledge of the person contacted.
C. Requests From or Visits by Governmental authorities
From time to time, the Company and its Personnel may be contacted by governmental agencies, regarding the COI or other matters. It is the Company’s policy to comply with applicable laws and regulations and to respond properly to all contacts, inquiries or requests made by governmental authorities. Personnel who have received prior approval to do so from the Company Executive Management may respond to routine contacts and inquiries from government agencies if they concern routine matters within the ordinary scope of their day- to-day responsibilities. Personnel should keep their supervisors informed as to the nature and scope of such contacts. All contacts, inquiries or requests, whether written or oral, by governmental authorities regarding matters that are not routine or are outside the scope of a Personnel’s day-to-day responsibilities should be immediately reported to the Personnel’s supervisor and the Officer before a substantive response is given. This will allow the Company to gather and evaluate any relevant information and to respond properly to the governmental authorities. Examples of matters that are not routine include, among other things, complaints, adverse claims, investigations, litigation, audits, regulatory exams, or other matters that could result in significant monetary or other liabilities.
Officers and Personnel are required to cooperate fully with all investigations by the Corporate Compliance Officer, the Company’s outside legal counsel or an authorized member of Internal Audit or of the Corporate Human Resources Department. In particular, they are required to respond truthfully, completely, and promptly to all inquiries.
E. Subpoenas or Other Legal Process
Only an authorized representative may accept legal process on behalf of the Company. If someone attempts to serve any person on behalf of the Company who is not an authorized representative, such person must decline to accept service and should immediately contact the Company Executive Management.
XI. Disciplinary Action and Violations of the Policy
Violations of this policy will be grounds for discharge or other disciplinary action, based on the circumstances of the particular violation. Disciplinary action will be taken, not only against individuals who authorize or participate directly in a violation of the policy, but also against any of the violator’s management, to the extent that the circumstances of the violation reflect inadequate supervision by the superior. Compliance with this policy will be a key factor in the evaluation of the individual’s overall performance.
If any colleague believes that he or she has been retaliated against in the form of an adverse Personnel action for disclosing information regarding misconduct under this policy, he or she may file a written complaint or a report to the Company’s ethics service requesting an appropriate remedy. It is the Company policy to encourage Personnel to come forward with any safety, ethical, or legal concerns. Retaliation against those who bring forward these types of related concerns or complaints will not be tolerated.
The Company will waive application of the obligations set forth in this policy only where circumstances warrant granting a waiver, and then only in conjunction with any appropriate monitoring of the particular situation. Waivers of the policy for Personnel must be approved by the Corporate Compliance Officer. Any waiver for the Corporate Compliance Officer must be approved by the Chief Executive Officer.
The policy is a statement of policies for individual and business conduct and does not, in any way, constitute an employment contract or an assurance of continued employment. Personnel of the Company provide services at-will, except when covered by an express, written employment/consulting agreement providing otherwise. This means that Personnel may choose to resign his or her services at any time, for any reason or for no reason. Similarly, the Company may choose to terminate a Personnel’ services at any time, for any legal reason or for no reason at all, but not for an unlawful reason.
The policy is not intended to and does not create any obligations to or rights in any colleague, director, customer, Vendor, competitor, or any other person or entity.
XIII. Reports of Suspected Misconduct and Questions
The Company has internal procedures which are to be followed in the case of any issues, questions, interpretations, required approvals, reports of conduct suspected to be in violation of this policy, or other matters regarding this policy. To report of suspected misconduct (i) the Personnel should contact his or her supervisor, Corporate HR, or the Corporate Compliance Officer and (ii) in any matter involving any Chief Executive Officer direct report, such person should contact the Chief Executive Officer. All reported violations will be promptly investigated and treated confidentially to the extent reasonably possible.
The policy cannot provide answers to all of our questions. If Personnel have questions about the policies set forth in this policy or are in doubt about the best course of action in a particular situation, they should consult with their manager or email Contracts@Innosoft.com.
XIV. Reporting Violations to a Governmental Agency
Personnel should understand that they have the right to:
- Report possible violations of state or federal law or regulation that have occurred, are occurring, or are about to occur to any governmental agency or entity.
- Cooperate voluntarily with, or respond to any inquiry from, or provide testimony before any federal, state or law enforcement authority;
- Make reports or disclosures to law enforcement without prior notice to, or authorization from, the Company; and
- Respond truthfully to a valid subpoena.
Personnel have the right to not be retaliated against for reporting, either internally to the Company or to any governmental agency or entity, information which they reasonably believe relates to a possible violation of the law. It is a violation of federal law to retaliate against anyone who has reported such potential misconduct either internally or to any governmental agency or entity. Retaliatory conduct includes discharge, demotion, suspension, threats, harassment, and any other manner of discrimination because of any lawful act. It is unlawful for the company to retaliate against you for reporting possible misconduct either internally or to any governmental agency or entity.
Notwithstanding anything contained in this policy or otherwise, Personnel may disclose confidential Company information, including the existence and terms of any confidential agreements between the Personnel and the Company (including employment, consulting or severance agreements), to any governmental agency or entity.
The Company cannot require Personnel to withdraw reports or filings alleging possible violations of Federal, State or local law or regulation, and the Company may not offer Personnel any kind of inducement, including payment, to do so.
Personnel’s rights and remedies as a whistleblower protected under applicable whistleblower laws, including a monetary award, if any, may not be waived by any agreement, policy form, or condition to provide services, including by a pre-dispute arbitration agreement.
Even if a Personnel has participated in a possible violation of law, he or she may be eligible to participate in the confidentiality and retaliation protections afforded under applicable whistleblower laws, and he or she may also be eligible to receive an award under such laws.