To provide a mechanism for employees, officers, directors, vendors and volunteers to raise good faith concerns regarding suspected violations of law and/or organizational policy on the part of Senior Services North Fulton (the “Organization”) or its employees and to protect individuals who take such actions from retaliation.
The Organization is committed to honesty, integrity and ethical practice in all areas of operation and expects all employees, board members, volunteers and vendors of the organization to act in accordance with the highest ethical standards in the performance of their responsibilities. It requires full compliance with all applicable laws and regulations and organizational policies and procedures. The Organization relies on all board members, volunteers and vendors of the Organization to conduct themselves in accordance with the requirements and spirit of this policy and to report any suspected violations of this policy or other questionable matters without fear of retaliation. This policy pertains to employees, officers, directors and volunteers.
It is the responsibility of all directors, officers, employees and volunteersto comply with all applicable laws and organizational policies, including the Organization’s Code of Ethics, and to report violations or suspected violations of laws or policies in accordance with this Whistleblower Policy. Volunteers are also encouraged to report any suspected violations and may do so without fear of retaliation.
No employee, officer, director or volunteer who in good faith reports a violation of an applicable law or policy shall suffer harassment, retaliation or adverse employment consequence. Any officer, director, employee or volunteer who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment or, for non-employees, termination of the individual’s affiliation with the Organization. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the Organization prior to seeking resolution outside the Organization. Those who believe they have been subjected to retaliation because they have made a report or participated in an investigation should immediately report such suspected retaliation to the Compliance Officer in the same manner as described under Reporting Violations.
The Organization encourages open communication and suggests that officers, directors, employees and volunteers share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, the Executive Director is in the best position to address the concerns of volunteers and employees, and the Board Chair is in the best position to address concerns of officers and directors. If an individual is not comfortable speaking with the Executive Director or Board Chair or is not satisfied with his/her response, the individual should speak with someone on the Board of Directors the individual is comfortable approaching or contact the Organization’s Compliance Officer directly. To facilitate a complete investigation, individuals reporting suspected violations should provide as many details as possible, including a description of the questionable practice or behavior, the names of any persons involved, the names of possible witnesses, dates, times and places, and any other available details.
The Executive Director, officers and members of the Board of Directors must immediately report any suspected violations of applicable law or policy to the Organization’s Compliance Officer. The Compliance Officer has a specific responsibility to investigate all reported violations. Any staff member, officer or director who fails to report suspected violations in accordance with this policy, or who otherwise fails to properly handle such allegations, may be subject to disciplinary action.
Notwithstanding the foregoing, all cases of suspected fraud should be reported directly to the Compliance Officer.
Compliance Officer Appointment and Responsibility
The Compliance Officer for the Organization will be the Chair of the Audit and Risk Management Committee of the Board of Directors. The Compliance Officer is responsible for investigating and resolving all complaints and allegations concerning violations of applicable law or policy. At his or her discretion, the Compliance Officer may advice the Executive Director and/or the Audit and Risk Management Committee of suspected violations.
Any person who has complaints or concerns about the Organization’s accounting, internal controls or auditing matters, or who becomes aware of concerns, should report such matters immediately. The Audit and Risk Management Committee of the Board of Directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The Compliance Officer shall immediately notify the Audit and Risk Management Committee of any such complaint and work with the Committee until the matter is resolved.
Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation of applicable law or policy must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. The Organization will not retaliate against individuals for complaints made in good faith. However, any allegations that prove not to be substantiated and which prove to have been made maliciously or when the individual knew the allegations to be false will be viewed as a serious disciplinary offense.
Violations or suspected violations may be reported on a confidential basis by the complainant or may be reported anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation and to correct unlawful or unethical practices.
Handling of Reported Violations
The Compliance Officer will acknowledge receipt of the reported violation or suspected violation within five business days of receipt. All reports will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation. The Compliance Officer will notify the individual who submitted the complaint when an investigation has been completed. A report on investigations and responses will be made to the Audit Committee of the Board of Directors at least annually.
J. Michael Webber
Chair, Audit and Risk Management Committee