Whistleblower Policy

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Montalvo Association
Whistleblower Policy Adopted April 17, 2006 The Montalvo Arts Organization’s Business Ethics and Conduct Code requires directors, other volunteers, and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of the organization must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations. Objectives: The objectives of the Montalvo Arts Organization’s Whistleblower Policy are to establish polices and procedures for: • The submission of concerns regarding questionable accounting or financial practices by employees, directors, officers, and other stakeholders of the organization, on a confidential and anonymous basis. Theft, working under the influence of alcohol or illegal drugs, sexual or other unlawful harassment, and other violations of the Business Ethics and Conduct Code as outlined in the Employee Handbook, Section 7.01, are also under the scope of this policy. • The receipt, retention, and treatment of complaints received by the organization regarding accounting, internal controls, financial and other business practices. • The protection of directors, volunteers and employees reporting concerns from retaliatory actions. Responsibility: Each director, volunteer, and employee of Montalvo Arts Organization has an obligation to report in accordance with this Whistleblower Policy any questionable or improper accounting or financial practices, or any violations or suspected violations of Montalvo’s Business Ethics and Conduct Code (hereinafter referred to as Concerns). All reported Concerns will be forwarded to the Audit Committee in accordance with the procedures set forth herein. The Audit Committee shall be responsible for investigating, and making appropriate recommendations to the Board of Directors, with respect to all reported Concerns. Retaliation: This Whistleblower Policy is intended to encourage and enable directors, other volunteers, and employees to raise Concerns within the Organization for investigation and appropriate action. With this goal in mind, no director, volunteer or employee who, in good faith, reports a Concern shall be subject to retaliation or, in the case of an employee, adverse employment consequences. Moreover, a volunteer or employee who retaliates against someone who has reported a Concern in good faith is subject to discipline up to and including dismissal from the volunteer position or termination of employment. Additionally, Montalvo will reinstate the reporting employee’s employment and work benefits, pay lost wages, and take other steps necessary to comply with the law. Reporting: Employees should first discuss their Concern with their immediate supervisor. If, after speaking with his or her supervisor, the individual continues to have reasonable grounds to believe the Concern is valid, the individual should report the Concern to the Manager of Human Resources. In addition, if the individual is uncomfortable speaking with his or her supervisor, or the supervisor is a subject of the Concern, the individual should report his or her Concern directly to the Manager of Human Resources. If an employee verbally reports their Concern to the Manager of Human Resources, the reporting employee, with assistance from the Manager of Human Resources, shall reduce the Concern to

writing. The Manager of Human Resources is required to promptly report the Concern to the Chair of the Audit Committee that has specific and exclusive responsibility to investigate all Concerns. If the Manager of Human Resources, for any reason, does not promptly forward the Concern to the Audit Committee, the reporting employee should directly report the Concern to the Chair of the Audit Committee. Contact information for the Chair of the Audit Committee may be obtained through the Human Resources Department. Concerns may also be submitted anonymously. Such anonymous Concerns should be in writing and sent directly to the Chair of the Audit Committee. Directors and other volunteers should submit Concerns in writing directly to the Chair of the Audit Committee. Contact information for the Chair of the Audit Committee may be obtained from the Chief Financial Officer. Investigation: The Audit Committee shall address all reported Concerns. The Chair of the Audit Committee shall immediately notify the Audit Committee, the Board President, the Executive Director, and the Chief Financial Officer of any such report. The Chair of the Audit Committee will notify the sender and acknowledge receipt of the Concern within five business days, if possible. It will not be possible to acknowledge receipt of anonymously submitted Concerns. The Audit Committee will promptly investigate all reports, and appropriate corrective action will be recommended to the Board of Directors, if warranted by the investigation. In addition, action taken must include a conclusion/follow-up with the complainant for complete closure of the Concern. If not satisfied with the outcome of the Audit Committee’s investigation, the reporting employee may report their Concern to the California State Attorney General’s Whistleblower Hotline at 1800-952-5225, as pursuant to the California Labor Code Section 1102.8. (a). The Attorney General will refer your call to the appropriate government authority for review and possible investigation. The Audit Committee has the authority to retain outside legal counsel, accountants, private investigators, or any other resource deemed necessary to conduct a full and complete investigation of the allegations. Acting in Good Faith: Anyone reporting a Concern must act in good faith and have reasonable grounds for believing the information disclosed indicates an improper accounting or financial practice, or a violation of Montalvo’s Business Ethics and Conduct Code. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in discipline, up to and including dismissal from the volunteer position or termination of employment. Such conduct may also give rise to other actions, including civil lawsuits. Confidentiality: Reports of Concerns, and investigations pertaining thereto, shall be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. Disclosure of reports of Concerns to individuals not involved in the investigation will be viewed as a serious disciplinary offense and may result in discipline, up to and including termination of employment. Such conduct may also give rise to other actions, including civil lawsuits.
Revised 4-17-06

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