(also found in revised Section 410 of the Staff Manual)

Purpose

In accordance with the Sarbanes-Oxley Act, the ASCB has instituted this policy to promote its corporate integrity and to enable employees and others to raise any serious concerns about suspected wrongdoing or fraudulent practices, to protect those who raise such concerns in good faith, and to provide a process for receiving and investigating such concerns.

Provisions of the Policy

  1. Filing of Complaints.
    ASCB employees, councilors, officers, and members are encouraged to report in good faith to the Treasurer, President, CEO or senior staff any violations of law or policy, any financial irregularities, and any suspected wrongdoing or conduct that could damage the Society’s good name, interests, and relationships with supporters, vendors, sponsors, and the community at large, as well as any attempts to conceal any such conduct.
  2. Confidentiality Permitted.
    Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
  3. Investigating, Handling, and Documenting Complaints.
    As determined by Council, the Finance/Audit Committee, the entire board or a committee composed solely of independent directors will supervise the adoption, implementation, and compliance of this Whistleblower Policy.

    In any given matter, the Council and senior staff shall ensure the investigation and resolution of all reported complaints and allegations of misconduct in a reasonably prompt manner. The resolution of such complaints or concerns shall be reported to the Council, to senior staff, and to the complainant, and shall include a report of any appropriate corrective action taken or planned to address the issues raised. The CEO shall maintain a record of all material complaints and concerns.

  4. Protection of Whistleblowers.
    No one who in good faith reports any suspected problem or wrongdoing shall suffer harassment, retaliation, or adverse employment consequence by the ASCB. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. Anyone who makes allegations in bad faith or without any reasonable basis can also be subject to discipline up to and including termination of employment.

Approved by Council 12-6-19