IMS’ Procedures for Addressing Program Participants’ Concerns

OVERVIEW

At Inner Matrix Systems (IMS) (“the Company”) we aim to foster good relations amongst participants and between participants and IMS staff. We acknowledge that your experience as a participant at IMS programming is shaped by how well you engage with your fellow participants and IMS staff. Should you have a concern related to the conduct of an IMS staff member or another participant, we encourage you to share your concerns by following the steps outlined below. IMS strives to create an inclusive and respectful environment. IMS does not condone or tolerate discrimination and/or harassment based on, without limitation, an individual’s race, national origin, ethnicity, age, disability, religion, sex, sexual orientation, and gender identity. IMS also does not tolerate bullying behavior, which may include threats of violence, intimidation, and/or objectively offensive statements directed at an individual that are not based on an individual’s protected class. If you experience behavior that potentially violates these behavioral standards, you should immediately report your concerns as outlined below.

The following procedure outlines steps you should follow to resolve concerns and the steps the Company will generally take to resolve your concerns should you raise a concern. Insofar as this policy imposes any obligations on the Company, those obligations are not contractual and do not give rise to any contractual rights. Nothing in this statement of the Company’s procedures to resolve concerns is intended to modify or impose greater obligations on the Company than are otherwise available under governing law. To the extent that this policy describes beneﬁts and entitlements for participants, they are discretionary in nature and are also not intended to be contractual.

The Company may unilaterally introduce, deviate from, vary, remove, or replace these procedures at any time.
WHAT ARE YOUR OPTIONS IF YOU HAVE A CONCERN?
In general, there are three options to consider if you have a concern:

Deal with the matter informally - You can try to resolve your concern informally by discussing it with those involved, but only if you feel comfortable doing so. By telling the person how their behavior, decision, or action impacted you, you will give them a chance to redress the situation. It is possible they did not realize how their behavior, decision, or action would affect you. This may not be appropriate in some cases, particularly if you do not feel comfortable speaking to that person.
Speak to an IMS staff member – If you do not want to speak to the person directly, you can tell an IMS staff member about your concern. They should be able to tell you what your options are. They may approach the person complained about and talk to them informally about your concern, or they may decide to take more formal action. Generally, they will seek your approval before doing anything; however, sometimes they may decide that taking action will be necessary even if you do not wish them to do so (for example, where a failure to act poses a health or safety risk). If your concern is about an IMS staff member, you may wish to speak to another senior person. Alternatively, you may decide to make a formal complaint.
Make a formal complaint – If you do decide to make a formal complaint, this can be done by putting the concern in writing and reporting it to the IMS Chief Operating Officer (or another senior person). The written complaint should contain a description of the incident(s), the time and date of the incident(s), the names of any witnesses, your signature, and the date of the complaint.

IF YOU MAKE A FORMAL COMPLAINT, HOW WILL IT BE HANDLED?
Formal complaints that are lodged in good faith will generally be handled in accordance with the following guidelines:

Complaints will be treated confidentially (except where the Company deems it is necessary to disclose the complaint for the purpose of dealing with it eﬀectively or where a legal obligation exits to report; if so, disclosure will be no wider than is strictly necessary). In order to facilitate the Company’s ability to conduct a review of the allegations and maintain the integrity of the process, we encourage you to maintain conﬁdentiality while the review is ongoing unless doing so would result in harm to yourself or others.
Complaints will be taken seriously, handled impartially, and addressed in accordance with the principles of procedural fairness.
Complaints will be dealt with promptly, taking into account the totality of the facts and circumstances.

Where a concern cannot be resolved informally, and the company deems an investigation is required, the matter will be investigated by such person as the Company deems appropriate. This may be an external investigation. How the investigation is conducted is within the complete discretion of the Company. The following are general guidelines:

During the investigation, you will generally be interviewed ﬁrst, following which any witnesses, the person against whom the complaint is made, and any other relevant people will be independently interviewed. If the complaint is substantiated, appropriate action will be taken (see below).

You will generally be provided with notice that an investigation has been completed; however, you may not be privy to the details of the Company’s findings and conclusions. If the complaint is demonstrably false as determined by the Company and made in bad faith, the Company reserves the right to deny participation in future programming.

WHAT ARE THE POSSIBLE OUTCOMES?
If the investigation reveals that your complaint is valid, a number of remedial actions may be taken by the Company within its sole discretion, depending on the nature of the complaint. Such actions are generally maintained in confidence and may not be visible to you.