Purpose
The Sarbanes-Oxley Act requires all organizations to establish procedures, in accordance with
Section 301 of the Act, for:
• The receipt, retention, and treatment of complaints received by the organization
regarding accounting, internal controls, or auditing matters.
• The submission of concerns regarding questionable accounting or audit matters by
employees, directors, officers, and other stakeholders of the organization, on a
confidential and anonymous basis.
The Community Partners’ Business Code of Conduct (hereinafter referred to as the Code)
requires directors, other volunteers, and employees to observe high standards of business and
personal ethics in the conduct of their duties and responsibilities. Employees and representatives of Community Partners must practice honesty and integrity in fulfilling their
responsibilities and comply with all applicable laws and regulations.
Reporting Responsibility
Each director, volunteer, and employee of Community Partners has an obligation to report in
accordance with this Whistleblower Policy (a) questionable or improper accounting or auditing
matters, and (b) violations and suspected violations of Community Partners’ Code (hereinafter
collectively referred to as Concerns).
Authority of Audit Committee
All reported Concerns will be forwarded to the Audit Committee in accordance with the
procedures set forth herein. The Audit Committee shall be responsible for investigating, and
making appropriate recommendations to the Board of Directors, with respect to all reported
Concerns.
No Retaliation
This Whistleblower Policy is intended to encourage and enable directors, volunteers, and
employees to raise Concerns within Community Partners for investigation and appropriate
action. With this goal in mind, no director, volunteer, or employee who, in good faith, reports a
Concern shall be subject to retaliation or, in the case of an employee, adverse employment
consequences. Moreover, a volunteer or employee who retaliates against someone who has
reported a Concern in good faith is subject to discipline up to and including dismissal from the
volunteer position or termination of employment.
Reporting Concerns
Employees
Employees should first discuss their Concern with their immediate supervisor. If, after speaking
with his or her supervisor, the individual continues to have reasonable grounds to believe the
Concern is valid, the individual should report the Concern to the Human Resources Manager or
Manager of Finance and Administration. In addition, if the individual is uncomfortable speaking
with his or her supervisor, or the supervisor is a subject of the Concern, the individual should
report his or her concern directly to the Human Resources Manager or Manager of Finance and
Administration.
If the Concern was reported verbally to the Human Resources Manager or Manager of Finance
and Administration, the reporting individual, with assistance from the Human Resources
Manager or Manager of Finance and Administration, shall reduce the Concern to writing. The
Human Resources Manager or Manager of Finance and Administration is required to promptly
report the Concern to the Chair of Audit Committee, which has specific and exclusive
responsibility to investigate all Concerns. If the Human Resources Manager or Manager of
Finance and Administration, for any reason, does not promptly forward the Concern to the
Audit Committee, the reporting individual should directly report the Concern to the Chair of the
Audit Committee. Contact information for the Chair of the Audit Committee may be obtained
through the Finance and Administration Department. Concerns may be also be submitted
anonymously. Such anonymous Concerns should be in writing and sent directly to the Chair of
the Audit Committee.
Directors and Other Volunteers
Directors and other volunteers should submit Concerns in writing directly to the Chair of the
Audit Committee. Contact information for the Chair of the Audit Committee may be obtained
from the Chief Financial Officer.
Handling of Reported Violations
The Audit Committee shall address all reported Concerns. The Chair of the Audit Committee
shall immediately notify the Audit Committee, the President, the Chief Executive Officer, and
Chief Financial Officer of any such report. The Chair of the Audit Committee will notify the
sender and acknowledge receipt of the Concern within five business days, if possible. It will not
be possible to acknowledge receipt of anonymously submitted Concerns.
All reports will be promptly investigated by the Audit Committee, and appropriate corrective
action will be recommended to the Board of Directors, if warranted by the investigation. In
addition, action taken must include a conclusion and/or follow-up with the complainant for
complete closure of the Concern.
The Audit Committee has the authority to retain outside legal counsel, accountants, private
investigators, or any other resource deemed necessary to conduct a full and complete
investigation of the allegations.
Acting in Good Faith
Anyone reporting a Concern must act in good faith and have reasonable grounds for believing
the information disclosed indicates an improper accounting or auditing practice, or a violation
of the Codes. The act of making allegations that prove to be unsubstantiated, and that prove to
have been made maliciously, recklessly, or with the foreknowledge that the allegations are
false, will be viewed as a serious disciplinary offense and may result in discipline, up to and
including dismissal from the volunteer position or termination of employment. Such conduct
may also give rise to other actions, including civil lawsuits.
Confidentiality
Reports of Concerns, and investigation pertaining thereto, shall be kept confidential to the
extent possible, consistent with the need to conduct an adequate investigation.
Disclosure of reports of Concerns to individuals not involved in the investigation will be viewed
as a serious disciplinary offense and may result in discipline, up to and including termination of
employment. Such conduct may also give rise to other actions, including civil lawsuits.
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