Whistle-Blower Policy

The Federation recognizes the great responsibility that is has for the careful management of the community dollars with which the organization is entrusted and prohibits unlawful or unethical behavior by any employee in connection with their work for the Federation. The organization and its officers have a responsibility to investigate and report to appropriate parties’ allegations of suspected improper activities and actions taken by the Federation. The Audit Committee will use the following procedures to investigate and resolve complaints received by the Federation concerning accounting, internal accounting controls, auditing matters, theft, fraud, misappropriation of funds, misleading financial information, spending or expending Federation or Agency funds for personal use, including any claim of retaliation for providing information to or otherwise assisting the Audit Committee. Any submissions by employees shall be received and maintained in a manner that assures confidentiality without compromising the submitter’s anonymity, if so requested by the submitter.

The following words, phrases or terms used in the Accounting Complaint Resolution Process shall have the following meanings:

• “Complaint” shall mean any report regarding questionable accounting, internal accounting controls, or auditing matters or theft or fraud;
• “Designated Person” shall mean the Chair of the Audit Committee or such other person or outside entity designated by the Audit Committee to receive Complaints;
• “Fact Finder” shall mean the person(s) or outside entity appointed by the Chair of the Audit Committee to investigate a Complaint; and
• Initiation of the Process:

“Fact Finding Report” shall mean the written report issued by the Fact Finder containing a summary of the facts learned in the Fact Finder’s investigation and the Fact Finder’s recommendations.

• The Complaint: To assure a correct understanding of the matters subject to the Complaint, the Complaint should be filed with the Designated Person in writing (although the Complaint may be made orally to the Designated Person if the person making the Complaint prefers) and should describe the accounting, internal accounting controls, or auditing matters or theft or fraud alleged. The Complaint should be as specific as possible and should identify any relevant documents and witnesses or other evidence that substantiates the Complaint. In order that prompt action can be taken, the Complaint should be filed as soon as possible.

  If the Complaint has been made orally, the Designated Person shall reduce the Complaint to writing. The Designated Person shall promptly forward the Complaint to the Chair of the Audit Committee if the Chair of the Audit Committee is not the Designated Person. If the person making the Complaint does not wish to maintain anonymity, the Complaint may be submitted to the employee’s immediate supervisor. Any person other than the Designated Person who receives a Complaint shall immediately forward the Complaint to the Designated Person.

• Commencement of Process: Upon receipt of a Complaint, the Chair of the Audit Committee shall appoint a Fact Finder (who may be the Chair of the Audit Committee) to investigate the Complaint and issue a Fact Finding Report. The Fact Finder shall deliver the Fact Finding Report to the Chair of the Audit Committee (or if the Fact Finder is the Chair of the Audit Committee, to the Audit Committee). For purposes of the investigation, the Fact Finder will report to the Chair of the Audit Committee.
• Confidentiality: Confidentiality – relating both to the fact that a Complaint has been made and to investigation of employee Complaints – will be maintained to the greatest extent possible. Only persons with a reason to know will have access to information relating to the Complaint and its investigation.

Fact Finding

• Investigation: The Fact Finder will conduct such investigation, as the Fact Finder deems appropriate, including interviews of persons who have information concerning the matters in question. Witnesses who are identified in the Complaint will also be interviewed. The Fact Finder will have access to all information and documents the Fact Finder deems relevant. The Designated Person will complete the investigation and the delivery of the Fact Finding Report as soon as practical after the receipt of the Complaint.
• The Fact Finding Report: The Fact Finding Report will concisely summarize the facts found by the Fact Finder and the Fact Finder’s recommendations. The Fact Finding Report shall be delivered to the Audit Committee.
• Evaluation of the Fact Finding Report: The Audit Committee will review the Fact Finding Report and may review other facts relating to the Complaint. Any decision of the Audit Committee regarding the subject matter of the Complaint will be communicated to the appropriate Federation executives and to the person filing the Complaint unless the Complaint was filed anonymously.

Potential Outcomes: If it is determined that improper accounting, internal accounting controls, or auditing matters or theft or fraud have occurred, the Audit Committee shall recommend that appropriate action be taken, including discipline of the wrongdoer(s). Discipline may take the form of counseling, verbal or written warning, reprimand, reassignment, suspension, demotion, and termination from employment, and/or prosecution.

Retaliation: It is unlawful to retaliate against an employee who has provided information or otherwise assisted in an investigation regarding a Complaint. Federation is committed to protecting employees from interference with making a claim and will not tolerate any coercion, intimidation, retaliation, interference or discrimination against any employee for making a claim or for assisting in the investigation of a Complaint.

Complaint File Retention: At the conclusion of the Process, the Audit Committee shall require the Federation to confidentially retain a copy of the Complaint, the Fact Finding Report, and any other documents deemed relevant by the Audit Committee, in the office of an outside law firm for the Federation for a period of three years from the date of the Complaint.