FIRST FEDERAL OF NORTHERN MICHIGAN BANCORP, INC.
Audit
Committee Complaints Procedures
The
Audit Committee of First Federal of Northern Michigan Bancorp, Inc. (the
Company) recognizes that the Company has a need to institute reasonable and
appropriate procedures for the reporting of concerns and complaints regarding
alleged accounting or auditing improprieties or inadequacies. In fact, the
Sarbanes-Oxley Act of 2002, Section 301 requires an audit committee to
establish procedures for the receipt, retention, and treatment of internal and
external complaints regarding accounting, internal accounting controls or
auditing matters, including anonymous employee reports.
Therefore,
the Company has developed the following procedures to address such complaints
and concerns:
1.
Internal
(employee) or external complaints and concerns may be addressed at any time to
the CFO, internal auditor or corporate secretary by calling toll-free (800)
498-0013 or (989) 356-9041. Written
complaints may be sent to the attention of the CFO, internal auditor or
corporate secretary at:
First
Federal of
100
S.
Alpena,
MI 49707
2.
If an employee who
wishes to remain anonymous has concerns regarding questionable accounting or
auditing matters involving the Company or if anyone external to the Company wishes
to make a complaint regarding the Company’s accounting, internal accounting
controls, or auditing matters, the complainant may, if he or she so chooses,
submit his or her concerns anonymously and confidentially to:
James
C. Rapin, Chair
Audit Committee
1125
3.
Upon receipt of
the report, the Audit Committee Chair shall review it and determine appropriate
action to take that may include circulation to the Audit Committee for further
deliberation and scheduling of a meeting. The Committee may, as provided in its
charter, retain independent advisors to investigate the allegations.
4.
The Committee
shall keep a log of all submissions including date submitted, actions taken,
and final disposition.
5.
To the extent that
the Audit Committee determines to communicate the report or findings outside
the Audit Committee, all directors should receive the communication. The Chair
or the full Committee may request management to investigate the allegation(s)
and report back to it. The Committee may provide a copy of the complaint or
allegation without identification of the complainant to the CEO, CFO, General
Counsel, or head of internal audit.
6.
The Committee
shall disclose results of its investigation to the CEO, CFO, General Counsel,
and head of internal audit, unless, of course, the investigation reveals any of
them are culpable, in which case the results shall not be disclosed to that
individual by the Committee.
7.
The internal audit
department shall periodically review all complaints submitted, without
identification of complainant, to determine if there is a pattern of conduct or
allegations that needs to be more thoroughly addressed.
8.
This procedure
shall be communicated to all employees and shall be posted on the Company’s
website.