Whistleblower Policy

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Whistleblower Policy

I. General

"__________, Inc. (the 'Organization') is dedicated to upholding lawful and ethical conduct
across all its operations. We expect our directors, officers, and employees to adhere to
applicable laws, regulations, and policies, and to maintain elevated levels of business and
personal ethics while performing their duties and responsibilities. As representatives of the
Organization, it is imperative that we demonstrate honesty and integrity in the fulfillment of our
roles."

II. Reporting

The Organization encourages its directors, officers, and employees to share questions,
concerns, suggestions, or complaints with the appropriate party. If anyone reasonably believes
that a policy, practice, or activity of the Organization is in violation of the law or Organization
policy, they should file a complaint with the President or the Chairman of the Board of Directors.
If the issue involves the President or the Chairman or if the reporting individual is not
comfortable contacting them, the matter may be reported to any member of the Board of
Directors. Violations or suspicions can be reported confidentially or anonymously. Reports will
be treated with confidentiality, to the extent possible, while conducting an adequate
investigation.

III. No Retaliation

Any employee who makes a good faith report under this Whistleblower Policy or who
cooperates in investigations shall not suffer harassment, retaliation or adverse employment
consequences. Any employee who retaliates against a co-employee who has reported a
violation in good faith is subject to discipline up to and including termination of employment. This
Whistleblower Policy is intended to encourage and enable employees, officers, and directors
and others to raise serious concerns within the Organization prior to seeking resolution outside
the Organization.

Any employee who believes that he or she has been subjected to any form of retaliation as a
result of making a good faith report under this Whistleblower Policy should immediately report
the retaliation to the director of Human Respurces.

IV . Investigation

The President, Chairman of the Board of Directors, or a representative of the Board of Directors
will notify the sender and acknowledge receipt of the reported violation or suspected violation
within five business days. All reports will be promptly investigated in a manner intended to
protect confidentiality, consistent with a full and fair investigation, and appropriate corrective
action will be taken if warranted by the investigation. A summary of the investigation will be
presented to the Board of Directors.

V. Accounting and Auditing Matters


The Board of Directors shall address all reported concerns or complaints regarding corporate
accounting practices, internal controls or auditing. The President or the Chairman of the Board
of Directors shall immediately notify the Board of Directors of any such complaint and work with
the Board until the matter is resolved.

VI. Acting in Good Faith

Anyone filing a complaint regarding a violation or suspected violation of Organization policies,


practices, or activities must do so in good faith and based on reasonable grounds. Allegations
that are unsubstantiated or found to be made maliciously or knowingly false will be considered a
serious disciplinary offense.

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