Code of Conduct

CODE OF BUSINESS CONDUCT AND ETHICS

The following code of business ethics was originally adopted by the board of directors of Atlantic Power Corporation (the "Issuer") on December 13, 2004, and most recently updated in March, 2007.

This Code of Business Conduct and Ethics covers a wide range of business practices and procedures. It does not cover every issue that may arise, but sets out basic principles to guide all directors, managers, officers and employees of the Issuer and its subsidiaries (collectively, "Atlantic Power Personnel"). All Atlantic Power Personnel must conduct themselves accordingly and seek to avoid even the appearance of improper behavior.

If a law conflicts with a policy in this Code, Atlantic Power Personnel must comply with the law. If a local custom or policy conflicts with this Code, Atlantic Power Personnel must comply with this Code. If you have any questions about these conflicts, you should ask a senior officer of the Manager how to handle the situation. Barry Welch, Chief Executive Officer of the Company, is the contact person for any questions regarding the Code (phone (617) 977-2400).

Atlantic Power Personnel who violate the standards in this Code will be subject to disciplinary action, up to and including termination of their employment or other relationship with the Issuer or its subsidiaries (collectively, the "Atlantic Power Entities"). If you are in a situation that you believe may violate or lead to a violation of this Code, follow the guidelines described below under "Compliance Procedures".

The Code

Compliance with Laws, Rules and Regulations
Obeying the law, both in letter and in spirit, is the foundation on which the Atlantic Power Entities' ethical standards are built and is critical to our reputation and continued success. All Atlantic Power Personnel must respect and obey the laws of the various jurisdictions in which the Atlantic Power Entities operate and avoid even the appearance of impropriety. Although not all Atlantic Power Personnel are expected to know the details of these laws, it is important to know enough to determine when to seek advice from executive members or other appropriate personnel. Barry Welch, Chief Executive Officer of the Company, is available to assist Atlantic Power Personnel in determining applicable legal requirements and to seek the advice of legal counsel where appropriate.

Conflicts of Interest
A "conflict of interest" exists when a person's private interests interfere in any way with the interests of the Atlantic Power Entities. A conflict of interest can arise when Atlantic Power Personnel take actions or have interests that may make it difficult for them to perform their work for an Atlantic Power Entity objectively and effectively. Conflicts of interest also may arise when Atlantic Power Personnel or members of their families receive improper personal benefits as a result of their positions with an Atlantic Power Entity.

Conflicts of interest are prohibited as a matter of policy, except as may be approved by the board of directors of the Issuer. Conflicts of interest may not always be clear-cut. If you have a question, you should consult with your supervisor or department head. Any Atlantic Power Personnel who become aware of a conflict or potential conflict should bring it to the attention of a supervisor or department head and consult the procedures described below under "Compliance Procedures".

Confidentiality
Atlantic Power Personnel must maintain the confidentiality of confidential information entrusted to them by any Atlantic Power Entity and persons with whom the Atlantic Power Entities do business, except when disclosure is authorized under the Confidential Information Policy or required by laws or regulations. Confidential information includes all non-public information that might be of use to competitors or harmful to any Atlantic Power Entity or the person to whom it relates if disclosed. The obligation to preserve the confidentiality of confidential information continues even after Atlantic Power Personnel cease to have a relationship with the Atlantic Power Entities.

Atlantic Power Personnel who have access to confidential information are not permitted to use or share that information for trading purposes or for any other purpose except the conduct of the Atlantic Power Entities' business. All Atlantic Power Personnel should read and abide by the Issuer's Confidential Information Policy,

Disclosure Policy and Insider Trading Policy

As a public entity, material information with respect to the Issuer and its subsidiaries must be disclosed to the public promptly and in a consistent manner. This obligation reflects the basic principle of securities regulation that all persons investing in securities should have equal access to information that may affect their investment decisions. The purpose of this policy is to establish a procedure for determining how material information is to be disclosed or disseminated. The following guidelines shall govern the disclosure process for the Issuer:

Disclosure of a material change in the affairs of the Issuer, whether favourable or unfavourable, must be disclosed to the public promptly and completely through a press release. With respect to the Issuer, the directors of the Issuer, in consultation with the Issuer's senior management, shall ultimately determine when a material change has or has not occurred. Any press release disclosing a material change shall be circulated at least contemporaneously to the directors if not previously reviewed by them. Announcements of material changes must be factual and balanced.

When the Toronto Stock Exchange ("TSX") is open for trading, prior notice of a press release announcing material information must be provided to the Market Surveillance Division of the TSX which will determine if a halt in trading is necessary to provide time for the market to digest the news. If a press release announcing material information is issued outside of trading hours, the Market Surveillance Division of the TSX should be notified before the market opens.

Disclosure of a material change must include any information the omission of which would make the rest of the disclosure misleading. Sufficient detail to enable the media and investors to understand the substance and importance of the change should be disclosed.

Selective disclosure is prohibited; previously undisclosed material information should not be disclosed to selected individuals such as analysts or institutional investors holding securities of the Issuer. In the event of inadvertent selective disclosure, the TSX should be contacted requesting a trading halt pending a press release and the information disclosed must be disseminated to the general public immediately.

Disclosure must be updated if earlier public disclosure becomes misleading in a material respect as a result of intervening events. In this regard, also see paragraph 14 below.

If material information is to be announced at an analyst meeting, a meeting of securityholders or a press conference, its announcement must be coordinated with the general public announcement by way of a press release.

Only non-material information and publicly disclosed information may be disclosed at private analyst briefings or meetings.
The following disclosure model should be used when making a planned disclosure of material information, such as a scheduled earnings release:

issue a news release containing the information through a widely circulated news or wire service;
provide advance public notice by news release of the date and time of a conference call, if any, to discuss the information, the subject matter of the call and the means for accessing it;
hold the conference call in an open manner, permitting investors and others to listen either by telephone or through Internet webcasting; and
provide dial-in and/or web replay or make transcripts of the call available for a reasonable period of time after the analyst conference call.

Analyst conference calls and industry conferences should be held in an open manner, allowing any interested party to listen either by telephone and/or through a webcast. Officials of the Issuer should meet before an analyst conference call, private analyst meeting or industry conference and, where practicable, statements and responses to anticipated questions should be scripted in advance and reviewed by the Chairman of the board of directors and/or the Chairman of the Audit Committee of the Issuer and/or the Chief Executive Officer of the Issuer.

Where practicable, records and/or transcripts of conference calls, meetings or industry conferences should be maintained and reviewed to ensure no unintentional selective disclosure of material non-public information has been made.

The Audit Committee of the Issuer and, if determined by such committee, the directors, must review: (i) earnings guidance disclosures; and (ii) news releases containing financial information based on the Issuer's financial statements prior to the release of such statements. A statement that the Audit Committee and/or directors have reviewed the disclosure should be included in the disclosure.

Where feasible, an earnings news release should be issued concurrently with the filing of the corresponding quarterly or annual financial statements.

Any review of an analyst's report concerning the Issuer should be limited to reviewing factual information to point out inaccuracies with respect to, or omissions from, recently released public information or to identify recently disclosed factual information that may affect the analyst's model and should not confirm the analyst's estimate or that any estimate is too high or too low, whether directly or indirectly, through implied guidance. Analyst's reports on the Issuer should not be posted on the Issuer's website and directors, managers, officers and employees of the Issuer and its subsidiaries should avoid taking any action that would be interpreted as an endorsement of an analyst's report.

When providing forward-looking information, it should clearly be indicated that, except as expressly required by applicable law, the Issuer undertakes no obligation to publicly update or revise any forward-looking statement, either as a result of new information, future events or otherwise. Notwithstanding this disclaimer, should subsequent events prove past statements to be materially off-target, the Issuer may choose to issue a news release explaining the reasons for the difference and updating its guidance on the anticipated impact on revenue and earnings.

From the close of business on the last day of the month of the fiscal quarter, or year, as applicable, until two business days following the Issuer's widespread public release of quarterly or year-end operating results, no director, manager, officer or employee should discuss or comment to outsiders on the status of the most recent quarter's or year's operations or their expected results or make any comments to outsiders as to whether the Issuer will meet, exceed or fall short of any earnings estimates made.

If material information has been leaked and appears to be affecting trading activity in the Issuer's securities, immediate steps should be taken to ensure that a full public announcement is made, including contacting the TSX and asking that trading be halted pending the issuance of a news release.

Until determined otherwise by the directors, the Chief Executive Officer of the Issuer shall be the designated contact person for communication with analysts, the news media and investors. All other employees who receive requests for undisclosed information should refer such requests to such officer and avoid answering any questions about the Issuer.

The board of directors of the Issuer has established a Disclosure Committee for overseeing the Issuer's disclosure controls and practices. The members of the Disclosure Committee may change from time to time, but at a minimum will include the following officers of the Issuer: the Chief Executive Officer, Chief Financial Officer and one additional officer.

The Disclosure Committee, in consultation with the board of directors where appropriate, will determine when developments justify public disclosure. At a minimum, the Disclosure Committee will meet quarterly in connection with preparation of annual or quarterly financial statements, related MD&A and the Issuer's Annual Information Form is underway.

It is essential that the Disclosure Committee be fully apprised of all material corporate developments to be able to determine whether there is information that should be publicly disclosed and what the appropriate timing is for release of that information. In some cases, the Disclosure Committee and the board of directors may determine that the information should remain confidential. If that is the case, they will determine how that information will be controlled so that it is not inadvertently released. It is therefore important that all individuals within the Issuer's organization, including its subsidiaries, make known to the Disclosure Committee material information relating to the Issuer. You must provide that information to the Disclosure Committee of the Issuer as soon as you become aware that it is, or may be, material. This applies throughout the year, but is particularly critical when preparation of annual or quarterly financial statements and MD&A or the Issuer's Annual Information Form is underway.

A "material change" in the affairs of the Issuer means a change in the business, operations or capital of the Issuer or its subsidiaries that could reasonably be expected to have a significant effect on the market price or value of any of the securities of the Issuer. A "material change" includes a decision to make such a change by the board of directors or by senior management of the Issuer who believe that board confirmation is probable. A "material fact" means a fact that would reasonably be expected to have a significant effect on the market price or value of the Issuer's securities. Material facts and material changes are collectively referred to in this policy as "material information". The following are examples of the types of events or information which may be material. This list is not exhaustive and is not a substitute for the board of directors of the Issuer, in consultation with the Issuer's senior management, exercising its own judgement in making materiality determinations.

Changes in Corporate Structure

changes in share ownership that may affect control of the Issuer;
major reorganizations, amalgamations, or mergers;
take-over bids, issuer bids, or insider bids;

Changes in Capital Structure

the public or private sale of additional securities;
planned repurchases or redemptions of securities;
planned splits of common shares or offerings of warrants or rights to buy shares;
any share consolidation, share exchange, or stock dividend;
changes in the Issuer's dividend payments or policies;
the possible initiation of a proxy fight;
material modifications to rights of security holders;

Changes in Financial Results

a significant increase or decrease in near-term earnings prospects;
unexpected changes in the financial results for any periods;
shifts in financial circumstances, such as cash flow reductions, major asset write-offs or write-downs;
changes in the value or composition of the Issuer's assets;
any material change in the Issuer's accounting policy;

Changes in Business and Operations

any development that affects the Issuer's resources, technology, products or markets;
a significant change in capital investment plans or corporate objectives;
major labour disputes or disputes with major contractors or suppliers;
significant new contracts, products, patents, or services or significant losses of contracts or business;
significant discoveries by resource companies;
changes to the board of directors or senior management, including the departure of the Chief Executive Officer, Chief Financial Officer or other senior officer (or persons in equivalent positions);
the commencement of, or developments in, material legal proceedings or regulatory matters;
conduct by a director or executive officer which constitutes a material departure from the Issuer's Code of Business Conduct and Ethics;
waivers of corporate ethics and conduct rules for officers, directors, and other key employees;
any notice that reliance on a prior audit is no longer permissible;
de-listing of the Issuer's securities or their movement from one quotation system or exchange to another;

Acquisitions and Dispositions

significant acquisitions or dispositions of assets, property or joint venture interests;
acquisitions of other companies, including a take-over bid for, or merger with, another company;

Changes in Credit Arrangements

the borrowing or lending of a significant amount of money;
any mortgaging or encumbering of the Issuer's assets;
defaults under debt obligations, agreements to restructure debt, or planned enforcement procedures by a bank or any other creditors;
changes in rating agency decisions; and
significant new credit arrangements.

External Political, Economic and Social Developments

Companies are not generally required to interpret the impact of external political, economic and social developments on their affairs. However, if an external development will have or has had a direct effect on the business and affairs of the Issuer that is both material and uncharacteristic of the effect generally experienced by other companies engaged in the same business or industry, the Issuer should explain, where practical, the particular impact on it. For example, a change in government policy that affects most companies in the Issuer's industry does not require an announcement, but if it affects the Issuer in a material way, the Issuer should make an announcement.

Information generally is "non-public" if it has not been widely disseminated through a major newswire service, national news service or financial service.

This disclosure policy should be reviewed annually and updated, as necessary, by the board of directors of the Issuer, which will also be responsible for:

developing and implementing the disclosure policy;
monitoring the effectiveness of and compliance with the disclosure policy;
ensuring that the Issuer's and its subsidiaries' directors, managers, officers and certain employees are educated with respect to disclosure issues and the disclosure policy;
reviewing and authorizing disclosure (including electronic, written and oral disclosure) in advance of its public release; and
monitoring the Issuer's website on a regular basis to ensure that: the website is up to date and accurate; all material information is dated when posted or modified; outdated information is moved to an archive; the archived material is retained for a reasonable period of time; all documents filed on SEDAR are concurrently posted to the website; and all material supplemental information not already publicly available given to analysts, investors and other market professionals are also posted on the website.

This policy may not cover all circumstances and exceptions may be justified from time to time. Any questions and all requests for exceptions from this policy should be made to the Chief Executive Officer of the Issuer, who will refer the request to the Disclosure Committee to determine whether or not it is appropriate to vary the policy in such circumstances.

Do not at any time actively "trade" in the securities of the Issuer (which include securities exchangeable into securities of the Issuer). For this purpose, "trading" means purchasing or selling with the expectation of making profit on a short term rise or fall of the market price. To limit the possibility of any suspicion of improper trading, any purchase or sale of securities of the Issuer should only be made for investment, and not speculative, purposes.
Do not undertake any trade (purchase or sale) of the securities of the Issuer without informing the Chief Executive Officer of the Issuer of such proposed trade.

Purchases and sales of securities of the Issuer may not be made from 10 days following the end of each of the fiscal quarters until 48 hours after the general release of the financial results for the quarter and may not be made from 10 days following the end of each fiscal year until 48 hours after the general release of the financial results for the year.

No purchase or sale of securities of the Issuer should be made with the knowledge of a material change in the affairs of the Issuer for at least 48 hours after the widespread public release of such change.
Until the widespread public release of a material change in the affairs of the Issuer, do not inform any other person about such change or discuss it with anyone other than in the necessary course of business.

Notification of Trades by Restricted Persons
In addition to these general guidelines applicable to everyone involved with the Issuer, directors, managers, officers and employees of the Issuer who are routinely in possession of undisclosed material information ("restricted persons") shall be required to inform the Chief Executive Officer of the Issuer in writing prior to engaging in any trade of securities of the Issuer.

"Material Change"
A "material change" in the affairs of the Issuer means a change in the business, operations or capital of the Issuer that could reasonably be expected to have a significant effect on the market price or value of any of the securities of the Issuer. A "material change" includes a decision to make such a change by the board of directors or by senior management of the Issuer who believe that board confirmation is probable. A "material fact" means a fact that would reasonably be expected to have a significant effect on the market price or value of the Issuer's securities. Material facts and material changes are collectively referred to in this policy as "material information".

Potential Sanctions
There are substantial statutory penalties for persons or companies where there has been a breach of the insider trading legislation. These penalties include fines up to $5 million (or triple any profit made or loss avoided by such contravention, whichever is greater), and prison terms of up to 10 years. In addition to statutory penalties, insider trading could cause the Issuer acute embarrassment and may result in disciplinary action against any employee who violates this policy, which may include in termination of employment.

This policy may not cover all circumstances and exceptions may be justified from time to time. Any questions and all requests for exceptions from this policy should be made to the Chief Executive Officer of the Issuer, who will determine whether or not it is appropriate to vary the policy in such circumstances.

Corporate Opportunities
Atlantic Power Personnel are prohibited from taking for themselves personally opportunities that are discovered through the use of corporate property, information or positions without the consent of the board of directors; and from using corporate property, information or positions for improper, personal gain. No Atlantic Power Personnel may compete with any of the Atlantic Power Entities directly or indirectly. Atlantic Power personnel owe a duty to each Atlantic Power Entity to advance its legitimate interests when the opportunity to do so arises.

Protection and Proper Use of Atlantic Power Entity Assets
All Atlantic Power Personnel should endeavor to protect Atlantic Power Entity assets and ensure their efficient use. Theft, carelessness and waste have a direct impact on the profitability of the Atlantic Power Entities. Any suspected incident of fraud or theft should be reported immediately to your supervisor or department head for investigation.

The obligation of Atlantic Power Personnel to protect the assets of the Atlantic Power Entities includes the Atlantic Power Entities' proprietary information. Proprietary information includes any information that is not known generally to the public or would be helpful to competitors of any of the Atlantic Power Entities. Examples of proprietary information include intellectual property (such as trade secrets, patents, trademarks and copyrights), business, marketing and service plans, designs, databases, salary information and any unpublished financial data and reports. Unauthorized use or distribution of this information would violate Atlantic Power Entity policy and could be illegal and result in civil or criminal penalties. The obligation to preserve the confidentiality of proprietary information continues even after Atlantic Power Personnel cease to have a relationship with the Company.

Atlantic Power Entities
Atlantic Power Entity assets may never be used for illegal purposes.

Competition and Fair Dealing
The Atlantic Power Entities seek to excel and to outperform any competitors fairly and honestly through superior performance and not through unethical or illegal business practices. Taking proprietary information without the owner's consent, inducing disclosure of that information by past or present employees of other persons or using that information is prohibited. Atlantic Power Personnel should respect the rights of, and deal fairly with, the Atlantic Power Entities' competitors and persons with whom the Atlantic Power Entities have a business relationship. No Atlantic Power Personnel should take unfair advantage of anyone through illegal conduct, manipulation, concealment, abuse of proprietary information, misrepresentation of material facts or any other intentional unfair-dealing practice. Nor should any Atlantic Power Personnel act in a manner that may be anti-competitive under anti trust laws. Barry Welch, Chief Executive Officer of the Company, is available to assist Atlantic Power Personnel in determining the application of those laws and to seek the advice of legal counsel where appropriate.

Gifts and Entertainment
Business gifts and entertainment are customary courtesies designed to build goodwill and constructive relationships among business partners. These courtesies may include such things as meals and beverages, tickets to sporting or cultural events, discounts not available to the general public, accommodation and other merchandise or services. In some cultures, they play an important role in business relationships. However, a problem may arise when these courtesies compromise, or appear to compromise, an Atlantic Power Entity's ability to make fair and objective business decisions or to gain an unfair advantage.

Offering or receiving any gift, gratuity or entertainment that might be perceived to unfairly influence a business relationship should be avoided. These guidelines apply at all times and do not change during traditional gift-giving seasons.

No gift or entertainment should ever be offered, given, provided, authorized or accepted by any Atlantic Power Personnel or their family members unless it is not a cash gift, is consistent with customary business practices, is not excessive in value, cannot be construed as a bribe or payoff and does not violate any laws. Strict rules apply when an Atlantic Power Entity does business with governmental agencies and officials (as discussed in more detail below). Atlantic Power Personnel should discuss with their supervisor or department head any gifts or proposed gifts about which they have any questions.

Payments to Government Personnel
All Atlantic Power Personnel must comply with all laws prohibiting improper payments to domestic and foreign officials. Other governments have laws regarding business gifts that may be accepted by government personnel. The promise, offer or delivery to an official or employee of various governments of a gift, favour or other gratuity in violation of these laws would not only violate the Atlantic Power Entities' policies but could also be a criminal offence. Illegal payments should not be made to government officials of any country. Barry Welch, Chief Executive Officer of the Company, can provide guidance to Atlantic Power personnel in this area.

Discrimination and Harassment
The diversity of Atlantic Power personnel is a tremendous asset. The Atlantic Power Entities are firmly committed to providing equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment of any kind. Examples include derogatory comments based on racial or ethnic characteristics and unwelcome sexual advances. Violence and threatening behavior are not permitted. Atlantic Power personnel are encouraged to speak with Barry Welch, Chief Executive Officer of the Company, when a co-worker's conduct makes them uncomfortable and to report harassment when it occurs.

Health and Safety
The Atlantic Power Entities strive to provide all Atlantic Power Personnel with a safe and healthy work environment. All Atlantic Power Personnel have responsibility for maintaining a safe and healthy workplace by following safety and health rules and practices and reporting accidents, injuries and unsafe equipment, practices or conditions to a supervisor or department head. Being under the influence, and the possession, of illegal drugs in the workplace will not be tolerated. Atlantic Power personnel should report to work in condition to perform their duties, free from the influence of illegal drugs or alcohol.

Accuracy of Records and Reporting
The Atlantic Power Entities require honest and accurate recording and reporting of information to make responsible business decisions. Each Atlantic Power Entity's accounting records are relied upon to produce reports for management, directors, managers, securityholders, governmental agencies and persons with whom the applicable Atlantic Power Entity does business. All of each Atlantic Power Entity's financial statements and the books, records and accounts on which they are based must appropriately reflect such Atlantic Power Entity's activities and conform to applicable legal, accounting and auditing requirements and to the Atlantic Power Entity's system of internal controls. Unrecorded or "off the books" funds or assets should not be maintained unless required by applicable law or regulation.

All Atlantic Power personnel have a responsibility, within the scope of their positions, to ensure that each Atlantic Power Entity's accounting records do not contain any false or intentionally misleading entries. The Atlantic Power Entities do not permit intentional misclassification of transactions as to accounts, departments or accounting records. All transactions must be supported by accurate documentation in reasonable detail and recorded in the proper accounts and in the proper accounting period.

Many Atlantic Power personnel use business expense accounts, which must be documented and recorded accurately. If Atlantic Power Personnel are not sure whether a certain expense is legitimate, a supervisor or department head can provide advice. General rules and guidelines are available from Barry Welch, Chief Executive Officer of the Company.

Business records and communications often become public through legal or regulatory proceedings or the media. Atlantic Power Personnel should avoid exaggeration, derogatory remarks, guesswork or inappropriate characterizations that can be misunderstood. This requirement applies equally to communications of all kinds, including e mail, informal notes, internal memos and formal reports.

WAIVERS OF THE CODE
Any waiver of this Code for directors, managers or executive officers may be made only by the directors (or a committee of the board of directors to whom that authority has been delegated) and will be promptly disclosed as required by law or stock exchange regulation.

REPORTING ANY ILLEGAL OR UNETHICAL BEHAVIOR
Each of the Atlantic Power Entities has a strong commitment to the conduct of its business in a lawful and ethical manner. Atlantic Power Personnel are encouraged to talk to supervisors, managers or other appropriate personnel about observed illegal or unethical behavior and when in doubt about the best course of action in a particular situation. It is the policy of the Atlantic Power Entities not to allow retaliation for reports of misconduct by others made in good faith. It is, at the same time, unacceptable to file a report knowing that it is false. All Atlantic Power personnel are expected to cooperate in internal investigations of misconduct.

COMPLIANCE PROCEDURES
All Atlantic Power personnel must work to ensure prompt and consistent action against violations of this Code. However, in some situations it is difficult to know right from wrong. Since we cannot anticipate every situation that will arise, it is important that the Atlantic Power Entities have a way to approach a new question or problem. These are the steps to keep in mind:

Make sure you have all the facts. In order to reach the right solutions, we must be as fully informed as possible.
Ask yourself: What specifically am I being asked to do? Does it seem unethical or improper? This will help you to focus on the specific question you are faced with and the alternatives you have. Use your judgement and common sense - if something seems like it might possibly be unethical or improper, it probably is.
Clarify your responsibility and role. In most situations, there is shared responsibility. Are your colleagues informed? It may help to get others involved and discuss the problem.
Discuss the problem with your manager. This is the basic guidance for all situations. In many cases, your manager will be more knowledgeable about the question and will appreciate being brought into the decision-making process. Remember that it is your manager's responsibility to help solve problems.
Seek help from company resources. In the rare case where it may not be appropriate to discuss an issue with your manager, or where you do not feel comfortable approaching your manager with your question, discuss it locally with your "two-up". If that is not appropriate for any reason, contact Barry Welch, Chief Executive Officer of the Company.
You may report ethical violations in confidence and without fear of retaliation. If your situation requires that your identity be kept secret, your anonymity will be protected. The Atlantic Power Entities do not permit retaliation of any kind against employees for good faith reports of ethical violations.
Always ask first, act later: If you are unsure of what to do in any situation, seek guidance before you act.