WHISTLE BLOWER COMPLAINTS
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.
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.
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.
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.