Davey: Corporate Conduct Reporting Policy "Whistleblower" Policy

Corporate Conduct Reporting Policy "Whistleblower" Policy

PURPOSE:
The Davey Tree Expert Company's Code of Ethics requires that all Company personnel (directors, officers and employees) observe high standards of business and personal ethics in the conduct of our duties and responsibilities. As representatives of the Company, we must practice sincerity and integrity in fulfilling our responsibilities and we must comply with internal policies and applicable laws and regulations. Accordingly, employees of the Company may discuss any concerns they have regarding compliance with laws and regulations or other violations of Company policy with members of senior management, Corporate Counsel, the Chief Executive Officer, or the Chairman of the Board of Directors, and have no fear of reprisal.

POLICY:
All Company employees are encouraged to report either orally or in writing to their immediate supervisor, or appropriate manager, all evidence of activity by a Company department or employee that may constitute:

Instances of corporate fraud
Unethical business conduct
A violation of Federal, State, Provincial or Local law
Substantial and specific danger to the employee's or public's health and safety
A violation of the Company's Code of Ethics

Any Company employee who in good faith reports such incidents will be protected from actual or threatened retaliation, discharge, or other types of discrimination, including compensation and conditions of employment, as a result of the disclosure of such reports. Further, no employee may be adversely affected because the employee refused to carry out a directive that, in fact, constitutes corporate fraud or is a violation of Federal, State, Provincial or Local law.

REPORTING VIOLATIONS:
The whistleblowing procedure is intended to be used for serious or sensitive issues. Anyone filing a complaint must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the Code of Ethics. Employment-related concerns should continue to be reported through your normal channels, such as your immediate supervisor or Human Resources in Kent.

Concerns can be reported in any of the following ways, and can be done anonymously:

Toll Free Telephone: 800.447.1667, Ext. 485
Internet Web: www.davey.com/corporate

Mailing address for written documents: Chairman of the Board
The Davey Tree Expert Company
1500 North Mantua Street
Kent, OH 44240

The Audit Committee of the Board of Directors shall address all reported concerns or complaints regarding known or suspected violations of the Code of Ethics for Financial Matters.

CONFIDENTIALITY:
Reports will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.