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SPAR GROUP, INC.
STATEMENT OF POLICY RESPECTING
EMPLOYEE COMPLAINTS AND COMMUNICATIONS
DATED AS OF NOVEMBER 4, 2003
(also known as the Whistleblower Policy)
The
Board of Directors (the “Board”) of SPAR Group, Inc. (together with its
subsidiaries, the “Company”), upon the approval and recommendation of its
Audit Committee, has adopted this SPAR Group, Inc. Statement of Policy Respecting Employee
Complaints and Communications Dated as of November 4, 2003 (also known as the
Whistleblower Policy) (as the same may be modified, amended, restated or replaced from
time to time in the manner provided herein, this “Policy”).
Any
employee, consultant or employee of any consultant to the Company or any of its affiliates
may at any time send any criticism, complaint or similar communication to the Company
respecting:
| (a) |
any accounting, internal control, auditing, reporting control or other public
disclosure matter, including any questionable practice or non-application, |
| (b) |
any violation of applicable law by the Company, any of its affiliates or any of
their respective officers, employees, consultants or other representatives; or |
| (c) |
any violation of any code or policy of the Company by the Company, any of its
affiliates or any of their respective officers, employees, consultants or other
representatives, including any ethics code or securities trading policy. |
These
messages may be sent without identifying the sender (i.e., anonymously) or may identify
the sender, at the option of the sender, in each case as follows:
(i) Sender Not
Identified (i.e., Anonymous)
CONFIDENTIAL
Audit Committee Chairman
SPAR Group, Inc.
560 White Plains Road Suite 210
Tarrytown, New York 10591
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The
Company should instruct its employees and consultants (who should be asked to remind their
respective employees) that anyone who sends such a message and does not want to be
identified should not sign the message or use stationary or envelopes with their name,
home address or business address. All documents received by the Company addressed as above
at least once per week shall be sent unopened to the Audit Committee Chairman at
such address as he may designate from time to time. |
(ii) Sender Identified
(i.e., NOT Anonymous)
Chief Financial Officer
SPAR Group, Inc.
560 White Plains Road Suite 210
Tarrytown, New York 10591
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If
the message relates to the Chief Financial Officer, the sender should send the message to
the Chairman instead. |
No
person will be subject to any discipline, penalty or other retaliation for in good faith
bringing any of the foregoing matters to the attention of the Company, including any good
faith satisfaction of his or her reporting obligations under any code or policies of the
Company or applicable law.
The
Company shall include a copy of this Policy in its handbook for employees. The Company or
the Audit Committee Chairman, as the case may be, shall maintain copies of all such
messages for at least three years.
The
Audit Committee Chairman shall advise the Company, and the Audit Committee Chairman and
the Chief Financial Officer shall advise the Audit Committee, from time to time respecting
each non-immaterial criticism, complaint or similar communication. The Company shall
respond as soon as reasonably practical, and to the extent deemed necessary or appropriate
by the Company or the Audit Committee, the Company shall endeavor to correct or otherwise
appropriately deal with the matter. The Company shall advise the Audit Committee from time
to time respecting its progress in any such matter.
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