Whistleblower Policy

Granite City Food & Brewery Investor Information

Granite City Food & Brewery Ltd. seeks to maintain 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 confidential, anonymous submission by employees of the Company of concerns regarding questionable accounting or auditing matters. Accordingly, the following procedures are hereby adopted:

  1. The Company’s Board of Directors shall receive and retain complaints received by the Company regarding auditing, internal accounting controls or auditing matters. Such complaints may be received in writing via hard copy or via email directly by the Board of Directors from a complaining person or, if received initially by an employee of the Company or a director of the Company, such complaints shall be transmitted to the Board of Directors. All such complaints shall be logged in by date and a file should be maintained by the Board of Directors containing each complaint, all documents and summaries relating to an investigation or inquiry concerning the complaint, together with the name of the complaining party, unless the complaint is by an employee requesting anonymous treatment.
  2. Any employee of the Company shall have the right to submit to the Board of Directors any concern regarding questionable accounting or auditing matters pertaining to the Company. Any such submission by an employee may be made in writing by a complaining employee, setting forth the nature of the concern regarding accounting or auditing matters and should provide the name, address and telephone number where the employee may be contacted to facilitate additional questions and provide the Board of Directors with an opportunity to follow-up on the employee's submission; provided however, any employee may submit to the Board of Directors concerns regarding questionable accounting or auditing matters on an anonymous basis. All employee submissions to the Board of Directors shall be treated as confidential and shall be maintained in confidential files of the Board of Directors.
  3. The Board of Directors shall promptly review and assess all complaints or employee submissions pursuant to these procedures. Where a complaint alleges or provides evidence of improper accounting, internal accounting controls, or auditing matters, the Board of Directors shall promptly investigate such complaint or submission.
  4. The Board of Directors shall have the authority to confer with Company officers and employees, legal counsel and independent auditors and may engage independent counsel and other advisors as it determines necessary to carry out its duties. The Company shall provide appropriate funding for the Board of Directors, including payment of fees to independent advisors.
  5. The Company shall notify all employees of the Company regarding these procedures and shall communicate the following in writing to all employees:

EMPLOYEE COMPLAINTS REGARDING QUESTIONABLE ACCOUNTING OR AUDITING MATTERS Granite City Food & Brewery Ltd. has established a procedure by which confidential complaints involving the Company's accounting, internal accounting controls or auditing matters may be submitted anonymously by employees to the Company’s Board of Directors. Complaints submitted through this confidential process that involves concerns by employees regarding questionable accounting or auditing matters should be presented in writing to the Company's Board of Directors. Attached to this notice is a form which employees may use to submit concerns regarding questionable accounting or auditing matters. All such submissions by employees will be maintained in a confidential file and will be reviewed and addressed by the Company's Board of Directors. It is the Company's policy to comply with all applicable laws that protect employees against unlawful discrimination or retaliation as a result of their lawfully reporting information regarding, or their participation in investigations involving, corporate fraud or other violations by the Company or its agents of federal or state law. This policy prevents any employee from being subject to disciplinary or retaliatory action by the Company or any of its employees or agents as a result of (1) the employee disclosing or submitting information to a government or law enforcement agency, or the Company's Board of Directors, where the employee has a reasonable belief that a violation or possible violation of federal or state law has occurred or is occurring, or (2) an employee providing information or assistance in an investigation or proceeding regarding any conduct that the Company reasonably believes involves a violation of federal or state law. EMPLOYEE SUBMISSION REGARDING QUESTIONABLE ACCOUNTING OR AUDITING MATTERS TO: Board of Directors Granite City Food & Brewery Ltd. c/o Eugene E. McGowan, McGowan Capital Group, 101 North Maine Avenue #325, Sioux Falls, SD 57104 gene@mcgowancapitalgroup.com

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Granite City Food & Brewery