Whistleblowing Policy

hrnewby

Does anyone have a whistleblowing policy they are willing to share? We are nonunion. Thank you in advance.

System

Hi there,

Below is our Whistleblowing Policy. We are a credit union so the verbiage may not apply to your company. Hope this helps anyway. If you have any questions, you are welcome to contact me at [email]ritar@qualstarcu.com[/email].

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WHISTLEBLOWER POLICY
(Effective 10/04)

Introduction
As a member-owned not-for-profit financial institution, Qualstar Credit Union is not required to implement policies under the “Sarbanes-Oxley Act of 2002” which provides protection against fraud within public companies. In reviewing Sarbanes-Oxley, however, it was decided that specific sections within the Act should be implemented in order to ensure fair and accurate accounting within the organization, and to protect employees in the event they witness unlawful practices. The following Whistleblower Policy applies to all officers, directors, employees and independent contractors of Qualstar Credit Union.

Policy Statement
All officers, directors, contractors and employees of Qualstar Credit Union are required to report and assist in any investigation by Qualstar Credit Union or any law enforcement agency concerning matters involving a violation of state or federal law, or conditions or practices that would put the health or safety of any employee at risk. This policy is intended to cover conduct by Qualstar officers, directors, contractors and employees that could have a large impact on Qualstar Credit Union, including such actions that:
• May lead to incorrect financial reporting;
• Are unlawful;
• Are a substantial and specific danger to health and safety;
• Lead to improper influence on conduct of audits or auditors;
• Are dishonest or unethical;
• Involve conflict of interest;
• Otherwise amount to serious improper conduct.

Confidentiality/Anonymous Allegations
Employees are encouraged to identify themselves when making an allegation of any violation in order for appropriate follow-up and investigation procedures to take place. Every effort will be made to protect a complainant’s identity; however, investigation may not be possible without the source of the information being identified, and all employees are on notice of that fact when they submit such a complaint or allegation. Concerns expressed anonymously will be investigated; however, consideration as to disclosure of the source will be given to:
• The seriousness of the issue raised;
• The credibility of the concern; and
• The likelihood of confirming the allegation from attributable sources.

Malicious Allegations
Although the employee is not expected to prove the truth of an allegation, the employee needs to demonstrate to the person contacted that there are sufficient grounds for concern. Allegations found to be made only with malicious intent may result in disciplinary action up to and including termination.

Protection from Harassment or Victimization
Qualstar Credit Union will protect employees who report in good faith to be a violation. No adverse personnel actions may be taken against a Qualstar Credit Union employee in knowing retaliation for disclosure of information on a matter of serious concern described in the “Policy Statement” above to the Board of Directors, Supervisory Committee, internal or external auditors, Federal or State regulators, law enforcement, or executive management.

Harassment or victimization of the complainant will not be tolerated including, but not limited to:
• Termination of employment;
• Demotion;
• Suspension;
• Written Reprimand;
• Retaliatory reprimand;
• Decision not to promote;
• Receipt of unwarranted performance rating;
• Withholding of appropriate salary adjustments;
• Imposition of involuntary transfer or reassignment;
• Elimination of employee’s position, absent of reduction in force, reorganization, or a decrease in or lack of sufficient funding or workload.
• Denial of awards, leave, benefits, or training for which the employee would normally be eligible;
• Other significant change in job responsibilities or working conditions that are inconsistent with the employee’s position, salary, or grade.

The fact that retaliation is not permitted does not in any way change the nature of the “at will” employment of all Qualstar Credit Union employees.

Procedures for Reporting a Complaint or Allegation
Employees should report a complaint or allegation as described in the “Policy Statement” above, first to the employee’s supervisor, an executive manager, or the CEO of the credit union. The supervisor or executive manager will work with the CEO to take prompt action to properly investigate the complaint or allegation. In the event that the concern involves the CEO, the employee may contact a member of the Qualstar Credit Union Board of Directors or Supervisory Committee. Subject to legal constraints, the complainant will receive information about the outcome of any investigations.

If a reported complaint or allegation of a violation is made directly to a member of Qualstar Credit Union management and not through the means provided in this Policy, such Qualstar Credit Union manager is required to communicate such complaint or allegation in accordance with this Policy.

Qualstar Credit Union reserves the right to modify or amend this policy at any time as it may deem necessary. All revisions will be brought before and approved by the Board of Directors.