Procedures for the Submission of Complaints or Concerns Regarding Financial Statement or other
Disclosures, Accounting, Internal Accounting or Disclosure Controls, Auditing Matters or
Violations of the Alico, Inc., Code of Business Ethics and Conduct
Section 301 of the Sarbanes-Oxley Act requires the Audit Committee of the Board of Directors of
Alico, Inc. (the Company) to establish procedures for: (a) the receipt, retention, and
treatment of complaints received by the Company regarding accounting, internal accounting
controls, or auditing matters; and (b) the submission by employees of the Company and others,
on a confidential and anonymous basis, of good faith concerns regarding questionable accounting
or auditing matters.
In accordance with Section 301, the Audit Committee has adopted the following procedures:
The Company shall promptly forward to the Audit Committee any complaints that it has received
regarding financial statement disclosures, accounting, internal accounting or disclosure
controls or auditing matters, disclosure violations or violations of its Code of Business
Conduct and Ethics.
Any employee of the Company may submit, on a confidential, anonymous basis if the employee so
desires, any good faith concerns regarding financial statement or other disclosure, accounting,
internal accounting or disclosure controls, auditing matters or violations of the Companys
Code of Business Conduct and Ethics. All such concerns shall be set forth in writing and
forwarded in a sealed envelope to the Audit Committee Chairperson in an envelope labeled with a
legend such as: To be opened by the Audit Committee only. Being submitted pursuant to the
Whistleblower Policy adopted by the Audit Committee. If an employee would like to discuss
any matter with the Audit Committee, the employee should indicate this in the submission and
include a telephone number at which he or she might be contacted if the Audit Committee deems
it appropriate. If the employee prefers an alternative method of contact, the employee may
contact the Companys Employee Whistleblower Hotline using the contact information set forth
below or may mail a complaint as indicated above to the Companys Employer Whistleblower post
office box using the address listed below.
Following the receipt of any complaint submitted hereunder, the Audit Committee will
investigate each such matter so reported and take corrective and disciplinary actions, if
appropriate, which may include, alone or in combination, a warning or letter of reprimand,
demotion, loss of merit increase, bonus or stock options, suspension without pay or termination
The Audit Committee may enlist committee members, Board members, employees of the Company
and/or outside legal, accounting or other advisors, as appropriate, to conduct any
investigation of complaints regarding financial statement disclosures, disclosure concerns or
violations, accounting, internal accounting controls, auditing matters or violations of the
Companys Code of Business Conduct and Ethics. In conducting any investigation, the Audit
Committee shall use reasonable efforts to protect the confidentiality and anonymity of the
The Company does not permit retaliation of any kind against employees for complaints submitted
hereunder that are made in good faith. Additionally, no employee shall be adversely affected
because the employee refuses to carry out a directive which, in fact, constitutes corporate
fraud, or is a violation of state or federal law or the Companys Code of Business Conduct and
The Audit Committee shall retain as a part of the records of the Audit Committee any such
complaints or concerns for a period of no less than seven (7) years.
Problems or concerns related to financial statement or other disclosures, accounting, internal
or disclosure controls, auditing matters or questions, disclosure violations or violations of
the Companys Code of Business Conduct and Ethics, which an employee wishes to discuss or
report on a non-confidential or non-anonymous basis, should be reported immediately to the
Companys Audit Committee Chairperson using the contact information specified below, or if the
employee is uncomfortable reporting to such person, to the Companys outside legal counsel
using the contact information specified below.
The Audit Committee Chairperson or outside counsel, as the case may be, shall keep a written
record of all such reports or inquiries and make monthly reports of the same to the Audit
Committee in any month in which an inquiry or complaint is received. If the contact is in the
nature of an alleged violation of the Companys Code of Conduct and Ethics or an impropriety
with regard to the Companys financial statements or other disclosures, accounting, internal or
disclosure controls, or auditing matters, the allegation shall immediately be relayed by the
Audit Committee Chairperson or the Companys outside legal counsel, to the Audit Committee, who
shall immediately notify the complainant that the complaint has been received and begin the
procedures outlined above.
Audit Committee Chairperson Evelyn DAn
DAn Financial Services
1301 NE 103rd Street
Miami Shores, FL 33138
Outside Legal Counsel David C. Shobe, Esq.
Fowler White Boggs Banker P.A.
501 East Kennedy Blvd.
Tampa, FL 33602
Whistleblower Mailing Address:
P O Box 339
LaBelle, FL 33975