The Audit Committee is responsible for monitoring developments applicable to this Code and may make such changes to the Code as may be appropriate. In addition, the Audit Committee reports regularly to the full Board of Directors with respect to issues that arise with respect to the Company’s compliance with legal or regulatory requirements, including the risk of criminal conduct. The Human Resources department is responsible for reviewing the day-to-day compliance by all employees with this Code and all other Human Resources policies and the issuance of related procedures regarding compliance. The General Counsel reports regularly to the Company’s Audit Committee and the Board of Directors regarding employees’ compliance with the Code and the overall effectiveness of the Code. The General Counsel, in coordination with the Human Resources department, will establish appropriate internal training programs concerning compliance and ethics matters for the Company’s directors, officers and other high-level personnel, as well as employees and agents of the Company.
Any waiver of this Code for executive officers, financial officers, managers or directors may be made only by the Board of Directors of Alpha Natural Resources, Inc. or a committee designated by the Board of Directors and will, if applicable, be promptly disclosed as required by applicable law or stock exchange regulation. All other waivers or determinations may be made by the General Counsel or his designee.