1. EFFECTIVE DATE.
This
2. PURPOSE.
3. REPORTING VIOLATIONS.
To report suspected violations, please write, email, or call one of the following resources:
- (a) Compliance Officers. Compliance officers are individuals who are responsible for reviewing and investigating reported violations.
has appointed the following associates to serve as compliance officers. Suspected violations can be reported to one of the following compliance officers: - (i)
; . (ii) ; . (iii) .
- (i)
(b) Anonymous Hotline. has created an anonymous hotline that allows individuals to report a suspected violation. If you want to use this service, please contact the hotline at . (b) (c) Alternative Reporting Options. If you feel uncomfortable reporting suspected violations to one of the compliance officers, or feel that your report has not been addressed properly, contactthe human resource director the general counsel the Chief Executive Officer ator .
4. ANONYMOUS REPORTS.
- (a) Reporters seeking 100% anonymity should
use either the anonymous hotline or report suspected violations by letter with no identifying details. - (b) Although
will use its best efforts to maintain the anonymity of reporters, in certain cases an individual's identity may need to be disclosed to conduct a thorough investigation, to comply with the law, or to provide accused individuals their legal rights of defense.
5. CONTENTS OF REPORT.
In general, a report should contain as much information as possible, including the facts and dates that led you to suspect that a violation occurred. Although you are not required to give your name in your report, contact information will allow the compliance officer to follow up with you with further questions.
6. ANONYMITY AND CONFIDENTIALITY.
Regardless of the method you use to report suspected violations,
7. INVESTIGATING AND RESOLVING REPORTS.
- (a) Documentation. When a report is received, the compliance officer will create a file for the suspected violation, and will keep all documentation in that file.
- (b) Timeframe. Investigation of violations shall begin within
days of receipt of the report. Every effort shall be made to investigate and resolve reports promptly.
8. COMPLIANCE OFFICERS' DUTIES.
Compliance officers shall use their best efforts to investigate thoroughly and with consideration for the reporter all reports of suspected violations. Compliance officers must report annually on the submission and resolution of these matters to
10. GOOD FAITH.
11. NO RETALIATION.
12. OTHER LAW.
Nothing in this policy may be construed in a way that conflicts with any reporting obligations or protections afforded by state or federal law.
How-to guides, articles, and any other content appearing on this page are for informational purposes only, do not constitute legal advice, and are no substitute for the advice of an attorney.
Whistleblower protection policy: How-to guide
Recently, there’s been a greater demand for transparency and accountability in the business world. Many organizations have implemented policies demonstrating their willingness to be open and accountable. One such policy is a whistleblower protection policy, which establishes procedures for employees to report illegal workplace conduct and protects these reporters from retaliation.
Several federal and state laws protect whistleblowers, and the laws vary from jurisdiction to jurisdiction. To show your employees that your organization wants to be responsible and ethical, create a whistleblower protection policy and include it in all employee handbooks and new hire packets.
Key elements to include in a whistleblower protection policy
The following instructions will help you understand the terms of your whistleblower protection policy. Please review the entire policy before finalizing your document.
Effective date
In this section, enter the name of your company and the date on which your policy becomes effective.
Purpose
This section explains the purpose of your policy and emphasizes that your company wants its employees to report good-faith concerns about illegal conduct in the workplace. Many nonprofit organizations extend this protection to include volunteers as well.
Reporting violations
This section describes how individuals can report illegal activities.
- Compliance officers: Enter the names and contact information of your company’s compliance officers. They should be trustworthy and easy to contact. If you have a large company, consider providing a longer list of individuals to whom reports can be made.
- Anonymous hotline: In this section, you can include if your company has created an anonymous hotline number to report unlawful contact.
- Alternative reporting options: This section provides alternatives if the reporter feels uncomfortable with the above options. This is essential if a suspected violation involves a compliance officer or the reporter thinks the officers aren’t taking a report seriously.
Anonymous reports
This section lists the company's genuinely anonymous means of reporting problems.
Contents of report
This clause reminds reporters to provide as much information as possible on their concerns. This section also notes that although reporters don’t have to include their names, it may be helpful to do so if compliance officers have additional questions.
Anonymity and confidentiality
Although your company’s policies allow for anonymous reporting, some reporting methods are inherently public. For example, a voice on a phone call may be recognizable, or handwriting can be identifiable. This section reminds your company’s employees to consider how they report problems if they wish to keep their anonymity.
Investigating and resolving reports
This section states that the compliance officer will keep all of the reports received in a file and indicates that an investigation of a report will begin promptly after it is received.
Compliance officers’ duties
This clause describes the reporting and investigative duties of compliance officers. Select the appropriate group to which reports will be made or add a separate group.
The compliance officers can contact the reporter if the original report isn’t anonymous.
Good faith
This section explains that reporters who make false reports may face disciplinary proceedings.
No retaliation
This clause informs employees that they won’t face adverse employment consequences because of reports they made in good faith.
Here, add the appropriate individual and their contact details to whom reports of retaliation should be made.
Other law
This section explains that the policy should be read consistently with all relevant laws.
Frequently asked questions
What is a whistleblower protection policy?
To be transparent about suspected unlawful activity, many companies have rules to protect people, sometimes called whistleblowers, who come forward to report potentially illegal actions. Protecting whistleblowers helps to root out any misdeeds and creates an environment where people feel safe to speak up without fear of retaliation. With a whistleblower protection policy, show that your business holds itself accountable.
What are the requirements for a whistleblower policy?
Here's the information you'll need handy to complete your whistleblower protection policy:
- Which company it's for: Know the name of the business issuing this policy.
- Reporting info: Be clear about how a person can report a suspected violation.
- Date and time: Note the date this policy will go into effect and how quickly internal investigations should begin, if necessary.
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