Ridgewood Energy Corporation (the “Ridgewood”) is subject to federal, state and local laws, regulations, rules and ordinances (such as anti-discrimination or harassment laws) and it has certain ethical and industry standards to which it must adhere in connection with its business, including its Code of Ethics (collectively, the “Standards”). In order to avoid violations of the Standards or other wrongdoing, Ridgewood has implemented formal reporting procedures so that every employee has a way of alerting Ridgewood’s management of on-going or possible violations of the Standards or other matters of which Ridgewood should be aware, without fear of reprisal.
Internal Reporting Procedures
- Who Receives a Report: Reports may be submitted to:
- to the CCO (in person at the NJO, by telephone at 201.447.9000 x2191 or by email at firstname.lastname@example.org); and/or
- the CFO (in person at the NJO, by telephone at 201.447.9000 or x2222; or by email at: email@example.com) and/or the COO (in person at the Houston office; by telephone at 281-598-5929 or x3226 or by email at firstname.lastname@example.org); and/or
- a direct supervisor or Senior Management personnel (See Schedule 1); and/or
- a federal, state or local regulatory or other law enforcement agency; and/or
- Report Form & Content: Reports should include as much detail as possible about the issue raised in the report, including for example, the date when the issue arose or on which the reporting employee became aware of the matter, the person(s) involved or responsible for the subject matter of the report, and any available documentation. Reports do not have to be in writing. If a person follows a different policy or procedure to file a report, such Report will be deemed to have been made in accordance and consistent with the terms of these Internal Reporting Procedures.
- Report Processing: Upon receipt of a report, the person receiving such report will bring it to the attention of the CCO. The CCO will review the report and will work with the CFO, COO, and/or the human resources department to determine the appropriate next steps. If the report was not delivered in writing, then the person receiving such report will provide the CCO with any notes such person may have taken during such conversation. Ridgewood may engage an independent third-party (such as outside counsel) to review the report and perform or guide the appropriate investigation.
- Confidentiality: Reports may be made anonymously, however, each person making a report should be willing to identify him/herself as necessary to assist in any required investigation or other action that Ridgewood may need to take in connection with the subject matter of the report. Every person who receives a report will treat the report confidentially to the extent possible and appropriate under the circumstances. Ridgewood takes all reports seriously and expects every person that makes a report to do so in good faith and not to embarrass someone or put them in a bad light.
- No Retaliation: Ridgewood will not permit or tolerate any retaliation against any employee who makes a good faith report under this procedure to Ridgewood or to any governmental or other law enforcement agency.Any employee who becomes aware or is the target of any retaliation should immediately report it to their immediate supervisor, the CFO, COO, the CCO or Human Resources. Every employee found to have retaliated against any other employee for making a good faith report under the procedures may be subject to criminal, civil and administrative penalties as well as disciplinary action, up to and including immediate termination of employment.
- Sanctions: If after an investigation, it is determined that a violation of the Standards has occurred, Ridgewood may impose sanctions as it deems appropriate under the circumstances, including but not limited to, letters of reprimand, suspension or termination of employment, and notification to regulatory or law enforcement agency (if warranted or required). The employment file(s) of the person(s) subject to the sanctions shall reflect the sanctions imposed and events/facts leading to such sanctions.
Effective: January 2022