I. Purpose
The Board values substantive input from stockholders and other interested parties. This Policy provides an orderly channel for communications concerning governance, strategy, Board oversight, ethics, accounting, and other matters appropriate for director attention.
II. How to communicate
Communications may be addressed to the Board, the Chair, a committee chair, or an individual director, care of the Corporate Secretary at the Company's principal executive office or through an electronic channel designated by the Company. The sender should provide a name, contact information, relationship to the Company, the intended recipient, the nature of the concern, and supporting information. Stockholders should identify the class and amount of securities held.
The Corporate Secretary may be reached through the Company's principal office or by telephone at 312-416-8586.
III. Screening and forwarding
The Corporate Secretary will log and review communications and forward substantive matters to the intended director or appropriate Board body. The Secretary may consult the Chair, Lead Independent Director, or counsel. Accounting, internal-control, auditing, fraud, bribery, sanctions, or retaliation concerns will be handled under the Whistleblower Policy and Audit and Risk Committee procedures.
IV. Communications not ordinarily forwarded
- Routine customer, supplier, employment, benefits, billing, or operational matters that management can address.
- Product solicitations, surveys, mass mailings, or commercial advertisements.
- Communications containing threats, unlawful content, obscenity, or abuse.
- Duplicative communications previously addressed, unless material new information is provided.
Screening will not be used to suppress credible allegations concerning directors, senior officers, accounting, legal violations, safety, environment, or retaliation.
V. Responses and records
Receipt may be acknowledged, but directors are not required to respond individually. The Board determines whether and how to respond. Records will be retained in accordance with legal holds and retention schedules, with appropriate confidentiality and privilege protections.
VI. Preservation of legal rights
This Policy does not restrict a stockholder's inspection rights under DGCL Section 220, rights under the Certificate, Bylaws, or stockholder agreements, or any person's right to communicate with regulators, law enforcement, or other protected recipients.
Administration
Implementation accountability rests with The Corporate Secretary. The responsible function will maintain this document and update it following a material legal, regulatory, operational, ownership, or business change.