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Whistleblower Policy

PURPOSE

The Audit Committee of West Suburban Bancorp, Inc. ("West Suburban") desires to provide all employees, officers and directors of West Suburban and its subsidiaries (collectively, the "Company") with mechanisms for employees and other interested parties to confidentially and anonymously bring to the attention of the Audit Committee any concerns related to matters covered by the Company's Code of Business Conduct and Ethics, legal issues and accounting or audit matters.

GENERAL OBJECTIVE

This Policy Regarding Communications with the Audit Committee describes the Company's process of collecting and organizing these communications and determining which communications will be relayed to the Audit Committee members.

ADMINISTRATION

This process is administered by the Company's Director of Internal Audit, is overseen by the Audit Committee and has been approved by the Audit Committee. Employees and other interested parties are able to report their concerns related to matters covered by the Company's Code of Business Conduct and Ethics, legal issues and accounting or audit matters to the Director of Internal Audit by:

  • Telephone at (630) 652-2207;
  • Pre-paid mail or courier to: Director of Internal Audit West Suburban Bank 711 S. Meyers Road Lombard, IL 60148; or
  • E-mail to Director of Internal Audit

COLLECTION OF COMMUNICATIONS

The Director of Internal Audit will collect all communications addressed as above or addressed to the Audit Committee (or any of its members). The Director of Internal Audit will review the communications to determine whether they are related to matters covered by the Company's Code of Business Conduct and Ethics, legal issues, accounting or audit matters ("Policy Scope Communications"). Any communications that are not Policy Scope Communications will be excluded from further processing under this Policy, and will instead be processed at the discretion of the Director of Internal Audit.

PROCESS

The Director of Internal Audit will maintain a log of all Policy Scope Communications and an original or a copy (which may be in an electronic format), of all Policy Scope Communications, which shall be kept in accordance with the Company's retention policy. The Director of Internal Audit will summarize all Policy Scope Communications that, in the view of the Director of Internal Audit, are of a length or a complexity such that summarization may improve the communication of the information contained therein.

REPORTING

The Director of Internal Audit will report on all Policy Scope Communications received since the immediately preceding report was provided to the Audit Committee members at least quarterly to the Audit Committee. The Director of Internal Audit will also provide to the Audit Committee Chairman, at least quarterly, a copy of all log entries made since the immediately preceding report was provided to the Audit Committee Chairman. The Director of Internal Audit will promptly provide to any Audit Committee member upon his or her request a copy of any part of the Policy Scope Communications log, a copy of any Policy Scope Communications and a copy of any summary of any Policy Scope Communications to the Audit Committee members.

ACTION OF DIRECTOR OF INTERNAL AUDIT

The Director of Internal Audit may immediately investigate and take any action he or she believes is necessary or appropriate in response to any matter raised in any Policy Scope Communication. At least quarterly, the Director of Internal Audit will report to all members of the Audit Committee, the actions taken, since the last report, in response to matters raised in any Policy Scope Communication.

PRIORITY REPORTING

If the Director of Internal Audit determines that a Policy Scope Communication presents credible evidence of (1) a material violation of any applicable securities law, (2) a material breach of fiduciary duty arising under any applicable law, or (3) a similar material violation of any applicable law, in each case by the Company or any officer, director, employee or agent of the Company, then the Director of Internal Audit shall promptly provide to the Audit Committee Chairman a copy of the Policy Scope Communication and report any relevant information known to the Director of Internal Audit and any actions taken in response to matters raised in the Policy Scope Communication.

ADMINISTRATION AND AMENDMENT

This policy regarding communications with the Audit Committee is subject and subordinate to the Audit Committee Charter. Accordingly, it may be amended or modified by the Board of Directors Audit Committee or as permitted under the Audit Committee Charter.

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