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Whistleblower Policy

POLICY NAME: WHISTLEBLOWER
POLICY NUMBER: COMP 4306 
APPROVAL DATE: JULY 17, 2019
POLICY OWNER: HUMAN RESOURCES 
SUPERCEDES: n/a
DATE REVIEWED:  n/a

Purpose  

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.  

email: concerns@nwworks.com 

password: nwW#elp1in3!  

Guidelines  

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: concerns@nwworks.com 

Password: nwW#elp1in3!  

2) Email the Chair of the Compliance Committee from concerns@nwworks.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 concerns@nwworks.com 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. 

Confidentiality  

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. 

Disclaimer  

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.

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