Complaint Management

Title. This Nonretaliation Policy (this “Policy”) is intended to comply with (a) Section 301 of the Sarbanes-Oxley Act of 2002 and the rules and regulations (including Item 406 of Regulation S-K of the Securities and Exchange Commission) promulgated thereunder (collectively, the “Act”), and (b) the listing requirements set forth in the Nasdaq Stock Market’s Marketplace Rule 4350(d)(3).
Applicability. This Code applies to all Web.com employees, officer and directors.
Policy: Web.com will not subject any employee, officer or director to any disciplinary or retaliatory action as a result of such person’s:
1. Disclosing to a federal law enforcement or government agency information such person has reasonable cause to believe evidences a violation or possible violation of federal, state or other applicable law or regulation; or
2. Providing information, causing information to be provided, or otherwise assisting in an investigation for a proceeding regarding any conduct that such person reasonably believes constitutes a violation of:
  1. federal criminal law relating to securities fraud, mail fraud, bank fraud, or wire, radio and television fraud, or
  2. any rule or regulation of the Securities and Exchange Commission, or
  3. any provision of federal law relating to fraud against shareholders,
  where the information or assistance is provided to or the investigation is being conduct by a federal regulatory agency, a member of Congress, or a person at Web.com with supervisory or similar authority over the employee; or
3. Filing, or causing to be filed, testifying, participating in, or otherwise assisting in a proceeding filed or about to be filed (to the knowledge of Web.com) relating to an alleged violation of:
  1. federal criminal law relating to securities fraud, mail fraud, bank fraud, or wire, radio and television fraud, or
  2. any rule or regulation of the Securities and Exchange Commission, or
  3. any provision of federal law relating to fraud against shareholders, or
4. Disclosing violations of Web.com’s Code of Conduct to Web.com personnel, federal law enforcement, governmental or regulatory agencies or bodies; or
5. Reporting violations of NASDAQ rules applicable to Web.com, including any trading in Web.com stock based on inside information to Web.com personnel, federal law enforcement, governmental or regulatory agencies or bodies.
Compliance Officer: Web.com has appointed a Compliance Officer who is responsible for administering this Policy. The Compliance Officer is responsible for receiving, collecting, reviewing, and processing complaints and reports by employees and others on the matters described in this Policy. Persons subject to this Policy are encouraged to discuss issues and concerns of the type covered by this Policy with their supervisors who, in turn, are responsible for informing the Compliance Officer of any concerns raised. If an employee of Web.com prefers not to discuss sensitive matters with his or her own supervisor, the employee may instead discuss such matters with the Compliance Officer or utilize the anonymous complaint procedure described in Section 5 below. The Compliance Officer will refer complaints arising under this Policy as directed by the Audit Committee of the Board of Directors.

Web.com’s Compliance Officer is the General Counsel, who may be reached at compliance@corp.web.com or by mail at Compliance Officer, Web.com, Inc., 303 Peachtree Center Avenue, Suite 500, Atlanta, Georgia 30303.
Complaint Procedure: Any officer, director or employee of Web.com may submit a complaint (a) regarding Web.com’s accounting, internal accounting controls, or auditing matters (including questionable accounting or auditing matters) (collectively, “Accounting Issues”) or (b) regarding Web.com’s compliance with any applicable U.S. federal or state law or regulation (collectively, “Legal Issues”), with the Compliance Officer by making a report through the EthicsPoint service available at www.ethicspoint.com. The identity of any Web.com employee submitting a complaint under this Policy will be kept anonymous if the person making such complaint so requests in the first submission made by such person. In addition, individuals who are not affiliated with Web.com may communicate complaints about Accounting Issues by submitting such complaints through www.ethicspoint.com. In the case of such individuals, the complainant must give his/her identity in the complaint.
Contents of Complaints: Persons submitting complaints under this Policy are encouraged to provide as much detail as possible so that the Compliance Officer and Audit Committee may determine the veracity of the report. Each such report should include:
1. When the subject activity occurred;
2. Who was involved;
3. The nature of the activity, Accounting Issue or Legal Issue (as applicable);
4. Why the activity is of concern;
5. What documentation exists regarding the activity, providing copies if possible;
6. Who else is aware of the activity; and
7. A list of actions already taken to bring this matter to the attention of Web.com or any third party and their response.
Record Keeping: The Compliance Officer will maintain a secure file with all reports received under this Policy. The Compliance Officer will maintain reports, and evaluations of those reports, for at least five years after the date when made, after which time such documents will be destroyed.
Reporting: The Compliance Officer will evaluate each report under this Policy and report to the Audit Committee on a periodic basis with respect to each such report and evaluation.
Limitations on Protected Disclosures: Employees, officers or directors who file reports or provide evidence that they know to be false or, in the case of Sections 3(a), 3(b), 3(d) and 3(e) of this Policy, who do not reasonably believe in the truth and accuracy of such information, are not protected by this Policy and may be subject to disciplinary action, including termination of employment.
Reporting Violations of this Policy: If an employee of Web.com believes he or she has been subjected to any action that violates this Policy, he or she may file a complaint with the Compliance Officer or the most senior officer in Web.com’s Human Resources Department. If it is determined that an employee has experienced any improper employment action in violation of this Policy, such employee will be entitled to appropriate corrective action.