ACE MARKETING AND PROMOTIONS, INC.
Whistleblower Policy

Revised December 19, 2008

Procedures for the Submission of Complaints or ConcernsRegarding Financial Statement Disclosures, Accounting, Internal Accounting Controls, Auditing Matters or Violations of the Company’s Code of Ethics or Corporate Code of Business Conduct 

Last Revised December 19, 2008

 

Section 301 of the Sarbanes-Oxley Act requires the Board of Directors of Ace Marketing and Promotions, Inc., (hereinafter “Ace” or the “Company”) to establish procedures for: (a) the receipt, retention, and treatment of complaints received by the Company regarding accounting, internal accounting controls, or auditing matters; and (b) the submission by employee, vendor or customers of the Company and others, on a confidential and anonymous basis, of concerns regarding questionable accounting or auditing matters.

 

In accordance with Section 301, the Company has adopted the following procedures:

 

1.The Company shall promptly forward to __________, as the Designee of the Board of Directors (hereinafter “Designee”), any complaints that it has received regarding financial statement disclosures, accounting, internal accounting controls or auditing matters.

 

2.Any employee, vendor or customer of the Company may submit, on a confidential, anonymous basis if the employee, vendor or customer so desires, any concerns regarding financial statement disclosures, accounting, internal accounting controls, auditing matters or violations of the Company’s Code of Ethics for Senior Financial Officers or Corporate Code of Business Conduct.  All such concerns shall be set forth in writing and forwarded in a sealed envelope to the Designee “To be opened by the Designee only.  Being submitted pursuant to the “whistleblower policy” adopted by the Company.”  If an employee, vendor or customer would like to discuss any matter with the Designee, the employee, vendor or customer should indicate this in the submission and include a telephone number at which he or she might be contacted if the Designee deems it appropriate. The contact address of the Designee is as follows:

 

___________________, Designee

Ace Marketing and Promotions, Inc.

457 Rockaway Avenue

Valley Stream, NY 11581

 

If an employee or vendor is not comfortable with contacting the Designee or believes that the Designee may have a conflict of interest in handling a complaint or concern, or if the Designee is unavailable and the matter is urgent, the employee or vendor may submit his or her complaint or concern marked “CONFIDENTIAL – TO BE OPENED BY ADDRESSEE ONLY” directly to Ace’s CEO and Member of the Board of Directors, Mr. Dean Julia, who may be contacted at:

 

Ace Marketing and Promotions, Inc.

457 Rockaway Avenue

Valley Stream, NY 11581

 

 

3. Following the receipt of any complaints submitted hereunder, the Designee will investigate each matter so reported and take corrective and disciplinary actions, if appropriate, which may include, alone or in combination, a warning or letter or reprimand, demotion, loss of merit increase, bonus or stock options, suspension without pay or termination of employment.

 

4.The Designee may enlist employees, vendors or customers of the Company and/or outside legal, accounting or other advisors, as appropriate, to conduct any investigation of complaints regarding financial statement disclosures, accounting, internal accounting controls, auditing matters or violation of the Company’s investigation, the Designee shall use reasonable efforts to protect the confidentiality and anonymity of the complaint.

 

5. All notices or reports of suspected violations, complaints or concerns received pursuant to this Whistleblower Policy shall be recorded in a log, indicating the description of the matter reported, the date of the report and the disposition thereof, and the log shall be retained in accordance with the Company’s document retention policies. This log shall be maintained by the Designee.

 

6. The reporting of complaints and concerns regarding auditing and accounting matters and/or violations of the Company’s Code of Business Conduct or Code of Ethics is strongly encouraged by Ace.  In accordance with the law, and the policies of Ace, retaliation of any kind against any employee of Ace who submits in good faith a complaint or concern regarding an auditing or accounting matter, or who assists in good faith in the investigation (whether by Ace or any regulatory authority or law enforcement agency) of any alleged wrongdoing involving an auditing or accounting matter or a violation of the Company’s Code of Business Conduct or Code of Ethics is strictly prohibited.  Acts of retaliation may result in severe disciplinary action against the individual(s) causing such retaliation, including termination of employment.