Whistleblower Policy

First Bricks Online Academy requires directors, officers, employees, interns and volunteers to observe high standards of professional and personal ethics in the conduct of all their duties and responsibilities. As employees and representatives of First Bricks Online Academy, we are to practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

In accordance with this policy, First Bricks Online Academy provides and enables a clear, systematic process through which all personnel affiliated with First Bricks Online Academy may address issues concerning noncompliance with applicable laws, regulations, and policies. Immediate investigation of and response to credible concerns are also mandated under this policy.

Reporting Responsibility

All directors, officers, employees, interns and volunteers have a responsibility to comply with First Bricks Online Academy’s policies and procedures and to report concerns regarding potential violations in accordance with this Whistleblower Policy. This Whistleblower Policy is intended to encourage and enable all employees and others to raise concerns internally so that First Bricks Online Academy can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees, interns and volunteers to report concerns about violations of First Bricks Online Academy’s code of ethics or suspected violations of law or regulations that govern First Bricks Online Academy’s operations.

No Retaliation

It is contrary to the values of First Bricks Online Academy for anyone to retaliate against any board member, officer, employee, intern or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of First Bricks Online Academy. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

Reporting Procedure

First Bricks Online Academy has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with Osman Dulgeroglu, Chief Executive Officer. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the First Bricks Online Academy’s Chief Executive Officer who oversees all organizational activities and has the responsibility to investigate all reported complaints and concerns. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or the Chief Executive Officer, Osman Dulgeroglu.

Supervisory and Executive Staff

All employees in supervisory and executive roles who receive notification of possible unethical or dishonest behavior are responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The supervisory and executive staff will advise the Chief Executive Officer and/or members of the Board of Directors of all complaints and their resolution and will report at least annually to the President of the Board of Directors, Dr. Nevzat Yilmaz on compliance activity relating to accounting or alleged financial improprieties.

Accounting and Auditing Matters

All employees in supervisory and executive roles are to address all reported complaints and concerns regarding First Bricks Online Academy’s corporate accounting practices, internal controls or auditing and work with the appropriate parties involved until the matter is fully resolved.


Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Acting in Good Faith

Anyone filing a written complaint concerning a violation or suspected violation of First Bricks Online Academy’s policies and procedures must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of First Bricks Online Academy’s policies and procedures. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.