POLICY NAME: WHISTLEBLOWER
POLICY NUMBER: COMP 4306
APPROVAL DATE: JULY 17, 2019
POLICY OWNER: HUMAN RESOURCES
DATE REVIEWED: n/a
NW Works requires its employees, volunteers, and Board of Directors to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. NW Works’ internal controls and operating procedures are intended to deter and prohibit activity that is contrary to NW Works’ policy, or is in violation of federal, state or local laws and regulations. Violations may include, but are not limited to:
- A violation of federal, state, or local law;
- Fraud or financial irregularities;
- Fraudulent financial reporting;
- Forgery or alteration of any documents;
- Unauthorized alteration or manipulation of computer files;
- The use of NW Works’ property, resources or authority for personal gain or for non-NW Works-related purpose except as authorized or provided under NW Works policy;
- Authorizing or receiving compensation for services not received or services not performed;
- Requesting reimbursement for expenses not incurred;
- Authorizing or receiving compensation for hours not worked;
- Activities endangering the health and safety of others.
All employees, volunteers, Board of Directors are expected and encouraged to report possible violations through appropriate NW Works procedures. Anyone concerned about possible retaliation may anonymously report serious violations of NW Works’ policies may anonymously report violations through the secure and confidential Whistleblower Google email address.
When submitting a complaint, we will need a clear and concise statement of the improper activity and any evidence you have to support the allegation. If you do not provide a name or other information (witnesses or documents) that clearly identifies the person you are alleging has acted improperly, we may not have the sufficient information to investigate. Copies of documents, rather than originals, should be submitted.
Although complaints may be filed anonymously, if insufficient information is provided and we have no means to contact you we may not be able to investigate your allegations. Serious concerns/complaints should be directed to the Chair of the Compliance Committee. Once logged in to the computer, you can obtain the Chairs’ email information in the contacts link. If you wish to remain anonymous, follow the whistleblower Procedure below:
1) Log into the official whistleblower gmail account using the information below.
Login ID: firstname.lastname@example.org
2) Email the Chair of the Compliance Committee from email@example.com with your detailed report.
3) IMPORTANT: Once the email has been sent, go to the sent folder and delete the email that you just sent.
4) Log out of the Gmail account. The sent email will be designated as firstname.lastname@example.org thus the sender will remain anonymous.
5) The Compliance Committee will investigate all reports filed in accordance with this policy with due care and promptness. The Compliance Committee shall have full authority to investigate concerns raised in accordance with this policy and may retain outside legal counsel, accountants, private investigators, or any other resource that the committee reasonably believes is necessary to conduct a full and complete investigation o the allegations.
Reports of concerns and investigations pertaining thereto, shall be kept confidential to the extent possible. However, consistent with the need to conduct an adequate investigation, NW Works cannot guarantee complete confidentiality. Disclosure of information relating to an investigation under this policy by staff, directors, or others involved with the investigation of concerns to individuals not involved in the investigation will be viewed as a serious disciplinary offense and, with respect to employees, may result in discipline, up to and including termination of employment. Depending on the circumstances, such conduct may also give rise to other actions, including civil or criminal lawsuits.
NW Works expressly reserves the right to change, modify or delete the provisions of this policy without notice. This policy is not intended to restrict communications or actions protected or required by all applicable local, state or federal law.
*This email is confidential and strictly for Whistleblower reporting.