VII. CORPORATE COMPLIANCE REPORTING

Under the general direction of the Corporate Compliance Officer, WNYIL Inc. and each Department Director shall implement processes to provide education and guidance on WNYIL Inc.'s ethics and legal compliance policies and procedures and for the reporting and investigation of business issues.

1. Each employee shall have responsibility to notify his or her supervisor in a timely manner, of any violations or suspected violations of the standards for ethics and legal conduct. In the alternative, an employee may follow the reporting procedure under Part IX, Fraud and Abuse Compliance Policy, Section C, Employee Participation and Reporting.
   
   Employees will be informed that in some instances, the mere failure to report a suspected violation may itself be a basis for disciplinary action against an employee.


2. A written procedure shall be developed and a toll-free telephone number (866) 576-8042 is available to all employees who may wish advice on certain policies and procedures, or who wish to report actual or perceived violations of law or applicable WNYIL Inc. policies and procedures.


3. Employees will not be subject to reprisal for reporting, in good faith, actions that they feel violate the law or established standards. Any employee engaging in any act of reprisal for any good faith reporting shall be subject to discipline and/or discharge.


4. Organizational Reporting
   
   The Corporate Compliance Officer shall report to the Executive Director regarding the Corporate Compliance Plan on an ongoing basis, report the activities of the Compliance Plan to the Corporate Compliance Committee at least quarterly, and report legal and ethics compliance as required.