Whistleblower Complaints
In accordance with the Policy and Procedure below, concerns/complaints submitted here will be forwarded anonymously to the Chairman of the Board of Directors:
POLICY
Parents And
Children Together (PACT) adheres to the highest
standard of conduct for its Board of Directors,
officers, employees, volunteers, advisory
boards, and consultants. In all actions in their
capacity as members of the PACT organization,
they assume the obligation to observe high
standards of business and personal ethics in the
conduct of their duties and responsibilities. As
employees and representatives of PACT, we must
practice honesty and integrity in fulfilling our
responsibilities and comply with all applicable
laws and regulations. It is the responsibility
of the Board of Directors, officers, employees
and other representatives of PACT to report
violations or suspected violations in accordance
with this policy and procedure.
This policy and
procedure has been developed to provide a
mechanism for employees and other
representatives of PACT to raise good faith
concerns regarding suspected violations of the
law on the part of PACT, to cooperate in an
inquiry or investigation by a court, law
enforcement, or other governmental body, or to
identify potential violations by PACT. The
policy also protects employees who take such
actions from retaliation.
The reporting
procedure is designed to protect the anonymity
and confidentiality of the person making the
complaint to the greatest extent possible.
However, the anonymity and confidentiality may
not be honored to the extent that it will hinder
the investigation of the complaint.
This policy and
procedure is based on people acting in good
faith to report concerns that they have reason
to believe are true. In the event that someone
makes unfounded allegations that are proven to
have been made recklessly, maliciously or with
the foreknowledge that the allegations were
false, the organization may take corrective
action against that person.
PACT has a
zero-tolerance policy for retaliation against
any employee or representative of PACT who, in
good faith, reports a suspected or actual
violation. The person making the complaint will
not experience abuse, harassment, threats,
discrimination or any adverse employment
consequences as a result of making the good
faith complaint. Any person who does retaliate
in any way is subject to immediate corrective
action, up to and including termination of
employment.
PROCEDURE
1. Reporting
Violations
A. This is
meant to be construed as an open door policy
and suggests that employees share their
questions, concerns, suggestions or
complaints with someone who can address them
properly. In most cases, an employee’s
supervisor is the best person to address an
area of concern. However, if an individual
is not comfortable speaking with his/her
supervisor or is not satisfied with a
supervisor’s response to the concern, that
employee is encouraged to speak with Human
Resource Director, the Vice President of
Operations, or the President & CEO. If the
employee is still not satisfied, the
employee can contact the Chair of the Audit
Committee of the Board of Directors. (Please
see attached for contact information).
If the
Compliance Officer (Vice President of
Operations) or the Vice President of
Programs are named in the complaint, the
complaint will be directed to the President
& CEO. If the President & CEO is named in
the complaint, the complaint will be
directed to the Chair of the Audit
Committee.
B. Members
of the Board of Directors and persons other
than employees will contact the Chair of the
Audit Committee.
C. Any
concerns relating to accounting practices,
internal controls or auditing go directly to
the Chair of the Audit Committee.
D. The
person reporting the violation will receive
acknowledgement of the complaint within 10
working days, once it is in the hands of the
Human Resource Director, the Vice President
of Operations, the President & CEO or the
Chair of the Audit Committee.
2. Investigation
A. PACT’s
Compliance Officer is the Vice President of
Operations. The Compliance Officer is
responsible for carrying out the
investigation regarding the complaints
identified above. The Compliance Officer
will document the findings and determine the
appropriate corrective action.
B. If the
concern or complaint involves actions by the
Compliance Officer or the Vice President of
Programs, the complaint will be made to the
President & CEO, who will conduct the
investigation and determine the corrective
action to be taken. If it is the President &
CEO who is named in the complaint, the
complaint will be made to the Chair of the
Audit Committee, who will conduct the
investigation, and in conjunction with the
Executive Committee and/or the full Board,
as deemed appropriate, will determine the
corrective action to be taken.
C. The
Compliance Officer reports the results of
any investigations to the Audit Committee on
an on-going basis and to the Executive
Committee of the Board on an annual basis.
D. The
Chair of the Audit Committee will conduct
all investigations related to violations
regarding accounting practices, internal
controls, or auditing. The Chair will report
all findings to the Executive Committee at
the conclusion of the investigation, along
with any corrective action plan.
3. Consequences
A. In the
event the allegations were made without good
faith, the employee making the complaint may
receive corrective action, up to and
including termination of employment.
Consultants and volunteers who make
complaints without good faith will have
their contracts and/or services
discontinued.
B. If there
was a violation of the code of ethics,
standards of conduct, confidentiality,
conflict of interest, accounting practices,
internal controls, or auditing the employee
or employees involved will receive
corrective action, up to and including
termination of employment.
C. Under no
circumstances will the person making the
complaint in good faith be subject to
retaliation in any form. Such retaliation
will result in corrective action, up to and
including termination. |
| PACT Parents And Children Together, 1485 Linapuni St. Suite 105mHonolulu, HI 96819, 1-808-847-3285 • 1-800-815-8413 |
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