Whistleblower Protection Policy

Scope and Purpose:

This Policy applies to all activities of Pharmacists Mutual Insurance Company, The Pharmacists Life Insurance Company, and Pro Advantage Services, Inc. (collectively referred to as PMC or the Company).

The purpose of this Policy is to encourage all individuals to disclose any wrongdoing that may adversely impact the Company, the Company’s policyholders, employees, or the communities in which the Company does business.  This Policy also outlines the individuals responsible for accepting reports and initiating the investigative procedures as well as the confidence and protection provided to the individual making the report.

Definitions:

Whistleblower – any person including employees, directors, officers, field representatives, customers, or community members who reports information regarding an actual, suspected, or anticipated wrongdoing within the Company.

Wrongdoing – examples of wrongdoing include, but are not limited to, fraud, violations of laws and regulations, violations of Company policies including the PMC Code of Ethics, falsification of Company documents, unethical behavior or practices, endangerment to public safety, and substantial mismanagement of Company resources.

General Guidance:

This Policy presumes that individuals will act in good faith and will not make false accusations.  An individual who knowingly makes false statements or disclosures may be subject to disciplinary actions.

Whenever possible, employees should try to resolve issues of wrongdoing by reporting them directly to their supervisor or to the next level of management as needed.  However, if the employee does not feel comfortable reporting to a supervisor or does not feel the complaint is being handled appropriately, the employee should report the issue to the Director of Internal Audit.  If the employee does not feel comfortable reporting this to someone within the Company, they may report directly to a member of the Audit Committee or the External Audit Partner.  The contact information for these individuals will be distributed to employees annually.

Any individual wishing to make a confidential and anonymous submission according to this Policy should address his or her concerns in writing and forward the same to the Director of Internal Audit, or other appropriate individual, in a sealed envelope marked with “CONFIDENTIAL”.

Director of Internal Audit
Pharmacists Mutual Companies
808 US Hwy 18 W
PO Box 370
Algona, IA 50511

Phone: 800.247.5930 ext. 7283