INTERNATIONAL AERIAL COMBAT SPORT FEDERATION | Whistleblower Protection Policy

INTERNATIONAL AERIAL COMBAT SPORT FEDERATION

Whistleblower Protection Policy

Confidential Reporting and Anti-Retaliation Procedures

Adopted Pursuant to IACSF Bylaws, Article XXV, Section 25.4

Effective: 2026

1. Purpose and Scope

The International Aerial Combat Sport Federation ("IACSF" or "Federation") is committed to lawful, ethical, and transparent operations. This Whistleblower Protection Policy ("Policy") establishes a confidential mechanism through which individuals may report suspected violations of law, the IACSF Bylaws, the Code of Ethics, or other Federation policies, and ensures that individuals who report in good faith are protected from retaliation.

This Policy applies to all members of the Board of Directors, the Commissioner, committee members, officers, employees, contractors, Member Teams, licensed participants, officials, and any other person associated with the Federation ("Eligible Reporters").

2. Reportable Conduct

The following types of conduct may be reported under this Policy:

• Violations of the IACSF Bylaws, Code of Ethics, Conflicts of Interest Policy, or Confidentiality Policy;

• Fraud, financial misappropriation, embezzlement, or other financial misconduct;

• Bribery, corruption, or improper payments;

• Manipulation of competition results or judging;

• Safety violations or concealment of safety incidents;

• Harassment, discrimination, or abuse involving Federation personnel or participants;

• Violations of applicable federal, state, or international law;

• Retaliation against any person for reporting a concern under this Policy;

• Any other conduct that the Eligible Reporter reasonably believes constitutes a serious violation of Federation standards.

3. How to Submit a Report

3.1 Reporting Channels

The IACSF shall maintain the following confidential reporting channels:

• Email: ethics@iacsf.org (monitored by the Commissioner or designated Ethics Officer)

• Written submission: Delivered in a sealed envelope marked “CONFIDENTIAL — ETHICS REPORT” to the IACSF Secretary-General

• Anonymous online portal: Accessible at [IACSF ethics reporting URL to be designated] (third-party administered)

• Direct report to the Board Chair: Appropriate where the report concerns the Commissioner or senior leadership

Reports may be submitted anonymously. Anonymous reports will be investigated to the extent possible given the information provided. The Federation encourages reporters to identify themselves where possible, as this generally enables a more complete investigation.

3.2 Information to Include

To the extent possible, a report should include:

• A description of the conduct believed to be in violation, including relevant facts, dates, locations, and persons involved;

• The identity of any witnesses or persons with relevant knowledge;

• Any documents, records, or other evidence supporting the report;

• The reporter’s contact information (unless reporting anonymously).

An incomplete report will not be disregarded; reporters should provide whatever information they have.

4. Good Faith Requirement

This Policy protects individuals who report concerns in good faith — that is, based on a reasonable belief that the reported conduct has occurred or is occurring. Reporters are not required to be certain that a violation has taken place, but reports must be made honestly and not for improper purposes such as competitive harassment or personal vendettas.

Bad faith reports — those known by the reporter to be false or substantially fabricated — are themselves a violation of the Code of Ethics and may subject the reporter to disciplinary action. This provision does not apply to reports that are investigated and determined to be unfounded, provided they were made in good faith.

5. Confidentiality of Reports

The IACSF shall handle all reports with strict confidentiality. The identity of the reporter shall not be disclosed to any person outside the investigative process without the reporter’s consent, except:

• Where disclosure is required by applicable law or court order;

• Where disclosure is necessary to conduct a fair investigation and cannot be avoided (in which case the reporter will be notified in advance, where possible); or

• Where the reporter has made their identity publicly known.

Personnel involved in receiving and investigating reports shall be bound by the IACSF Confidentiality Policy. All reports, investigation files, and related communications shall be maintained in a secure, access-restricted system.

6. Investigation Procedures

6.1 Intake and Triage

All reports received through the reporting channels shall be acknowledged within five (5) business days (or as promptly as practicable for anonymous reports). The Commissioner or designated Ethics Officer shall review each report to assess its credibility and determine the appropriate scope of investigation.

6.2 Investigation

Reports that present credible information of potential violations shall be investigated promptly and thoroughly. The investigation may be conducted by:

• The Commissioner or designated Ethics Officer, for matters not involving senior Federation leadership;

• An independent outside investigator appointed by the Board, for matters involving the Commissioner, Directors, or where independence requires;

• The Judicial and Disciplinary Committee, consistent with the procedures of Bylaws Article XX.

All persons involved in an investigation — including investigators, witnesses, and subjects — are required to cooperate fully and honestly. Obstruction of an investigation is a serious violation of this Policy and the Code of Ethics.

6.3 Timing

The IACSF shall endeavor to complete investigations within sixty (60) days of receipt of the report, where practicable. Complex matters may require additional time. The reporter (if identified) shall be informed of the general status of the investigation at reasonable intervals.

6.4 Outcome

Upon completion of an investigation, the Commissioner or investigator shall prepare a written summary of findings and recommended actions. The Commissioner shall present the findings to the Board (or appropriate committee) for action consistent with the disciplinary procedures of Bylaws Article XX. The reporter shall be notified, in general terms, that the investigation has been completed, consistent with applicable confidentiality obligations.

7. Anti-Retaliation Protection

7.1 Prohibition on Retaliation

The IACSF strictly prohibits retaliation against any Eligible Reporter who, in good faith:

• Submits a report under this Policy;

• Participates in or cooperates with an investigation conducted under this Policy or any other Federation proceeding;

• Refuses to participate in conduct that they reasonably believe violates applicable law or Federation policy; or

• Exercises any right protected by applicable law.

"Retaliation" includes any adverse action taken against a reporter because of their protected conduct, including but not limited to: termination of employment or contract; demotion; exclusion from competitions or events; suspension of Federation rights; harassment; hostile treatment; and any other action intended to punish, intimidate, or discourage the reporter.

7.2 Reporting Retaliation

Any person who believes they have experienced retaliation for engaging in protected conduct under this Policy shall report it immediately through the reporting channels in Section 3 or directly to the Board Chair. Retaliation complaints shall be investigated with the same urgency and confidentiality as other reports under this Policy.

7.3 Consequences for Retaliation

Retaliation against a reporter is a serious violation of this Policy and the IACSF Code of Ethics, and may result in disciplinary action under Bylaws Article XX, including removal from office, suspension, or expulsion, irrespective of the outcome of the underlying report.

8. No Waiver of Rights

Nothing in this Policy is intended to waive, limit, or restrict any right that an Eligible Reporter may have under applicable law to report suspected violations to any governmental authority, regulatory agency, or law enforcement body. The Federation shall not take any action to interfere with or penalize the exercise of such rights.

9. Record-Keeping

The Secretary-General shall maintain a secure register of all reports received under this Policy, including the date of receipt, the general nature of the concern, the status of investigation, and the outcome. Individual report files shall be maintained in a secure, access-restricted system for a minimum of seven (7) years. The existence and content of individual reports shall be treated as Confidential Information under the IACSF Confidentiality Policy.

10. Non-Exclusivity

This Policy establishes a minimum reporting framework. Nothing in this Policy prevents the IACSF from investigating potential violations that come to its attention through means other than a formal report under this Policy, or from taking appropriate action with respect to any violation regardless of how it is discovered.

11. Review and Amendment

This Policy shall be reviewed at least every two (2) years by the Board of Directors and amended as necessary to reflect changes in applicable law, best practices, or Federation operations. Amendments shall be approved by majority vote of the Board.

Adopted by the Board of Directors of the International Aerial Combat Sport Federation, 2026.