WhistleBlower Policy & Form

DGSE Companies, Inc. is committed to promoting ethical and honest behavior and ensuring that our co-workers, suppliers, vendors and partners feel safe and secure in their work environment. In support of this commitment, we operate an anonymous Whistleblower Service through a toll free number (800-916-7037) to facilitate reporting by co-workers and others of potential misconduct in the workplace, including:

  • Theft
  • Harassment
  • Fraud
  • Unethical/illegal behavior
  • Dishonesty
  • Workplace safety hazards
  • Discrimination
  • DGSE’s Whistleblower Policy ensures that, in line with regulatory requirements, co-workers can raise concerns regarding alleged inappropriate conduct in good faith. Each concern raised is properly investigated without the subject or reporting party being subjected to harassment or discriminatory treatment. Whistleblower matters are reported to the Board of Directors immediately upon receipt.


    Process:

    Receipt of Complaints –

    The Board of Directors will be involved in the treatment of these complaints, led by at least one independent Board member.

    Employees:

    Complaints may be submitted regarding an individual’s respective concern about possible corporate misconduct in the workplace. These concerns are treated in a confidential, anonymous basis through our toll-free Whistleblower hotline.

    Non-employees:

    Includes any business that engages, in whole or in part, in the manufacturing, wholesale or retail sale of jewelry or any other aspect of the company's business.

    Treatment of Complaints:

    The treatment of all complaints will be subject to the oversight of the Board of Directors. Upon receipt of a complaint regarding any matter, the Lead Independent Director will evaluate the complaint, discuss the complaint with the chief executive officer if appropriate, and determine if the complaint should be forwarded to all independent directors. Once reviewed, the Board of Directors, senior management and legal counsel, if appropriate, will determine a recommended course of action. This may include an investigation conducted with the involvement of an independent committee or group to assist in the investigation into the complaint. Once completed, the company’s Lead Independent Director will report his recommendation. Prompt and appropriate corrective action will be taken in response to all complaints as warranted in the judgment of the Board of Directors. Individual’s confidentiality will be maintained to the extent reasonably possible throughout the course of all such investigations. DGSE will not terminate, demote, suspend, threaten, harass, or in any manner discriminate or retaliate 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 any possible corporate misconduct, nor take any other action prohibited by Section 806 of the Sarbanes-Oxley Act of 2002.

    Retention of Complaints:

    The Company’s Secretary will maintain a log of all complaints. The log will note the receipt, investigation, and resolution of each complaint. Copies of the complaints will be retained for five years following the termination of the course of action taken in response any allegations.