| Anonymous Complaints Policy
Download
a PDF version of this policy.
Complaint Procedures for Accounting,
Internal Accounting Controls and Auditing Matters
Any employee of First South Bancorp, Inc. (the “Company”),
including employees of First South Bank (the “Bank”)
and/or subsidiaries of the Company or the Bank, may
submit a good faith complaint regarding accounting,
internal accounting controls, auditing matters, or suspected
fraud to the management or board of the Company without
fear of dismissal, reprisal, or retaliation of any kind.
In addition, any person, including employees of the
Company or the Bank, may submit good faith complaints
regarding accounting, internal accounting controls or
auditing matters with confidence that the matter will
be investigated thoroughly with appropriate remedial
action taken if necessary. The Company is committed
to achieving compliance with all applicable securities
laws and regulations, accounting standards, accounting
controls and audit practices. The Company’s Audit
Committee will oversee treatment of concerns in this
area.
In order to facilitate the reporting of employee and
non-employee complaints, the Audit Committee of the
Company’s Board of Directors has established the
following procedures for (1) the receipt, retention
and treatment of complaints regarding accounting, internal
accounting controls, auditing matters, or suspected
fraud (“Accounting Matters”), and (2) the
confidential, anonymous submission by employees of concerns
regarding questionable accounting, auditing, or other
matters.
Receipt of Complaints
-
Persons, including employees,
with concerns regarding Accounting Matters
may report their concerns to the Chairman
of the Audit Committee of the Company.
-
Employees may forward
concerns regarding questionable accounting
or auditing matters on a confidential or anonymous
basis to the Audit Committee Chairman through
regular mail at the following address:
|
Mr. Marshall T. Singleton
Chairman, Audit Committee
920 W. 3rd Street
Washington, NC 27889
Scope of Matters Covered by These Procedures
These procedures relate to concerns regarding any questionable
accounting or auditing matters, including, without limitation,
the following:
-
Fraud or deliberate error
in the preparation, evaluation, review or
audit or any financial statement of the Company;
-
Fraud or deliberate error
in the recording and maintaining of financial
records of the Company;
-
Deficiencies in or noncompliance
with the Company’s internal accounting
controls;
-
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; or
-
Deviation from full and
fair reporting of the Company’s financial
condition or results of operations.
|
Treatment of Complaints
-
Upon receipt of a complaint,
the Audit Committee Chairman will (i) determine
whether the complaint actually pertains to
Accounting Matters and (ii) when possible,
acknowledge receipt of the complaint to the
sender.
-
Complaints relating to
Accounting Matters will be reviewed under
Audit Committee direction and oversight by
such person(s) as the Audit Committee determines
to be appropriate. Confidentiality will be
maintained to the fullest extent possible,
consistent with the need to conduct an adequate
review.
-
Prompt and appropriate
corrective action will be taken when and as
warranted in the judgment of the Audit Committee.
-
The Company will not discharge,
demote, suspend, threaten, harass, or in any
manner discriminate against any employee in
the terms and conditions of employment based
upon any lawful actions of such employee with
respect to good faith reporting of complaints
regarding Accounting Matters or otherwise
as specified in Section 806 of the Sarbanes-Oxley
Act of 2002.
Reporting and Retention of Complaints and
Investigations.
-
The Chairman of the Audit
Committee shall maintain a log of all complaints
and concerns, tracking their receipt, investigation
and resolution, and shall prepare a periodic
summary report thereof for the Audit Committee.
Copies of complaints and such log will be
maintained in accordance with the Company’s
document retention policy.
|
Last Updated: August 3, 2020
|
