Our Policy
Whistleblower Policy: Reporting Suspected Violations of Law and Policy
The Early Learning Coalition of Palm Beach County requires all employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the Coalition prior to seeking resolution outside the Coalition.
a. Reporting Responsibility
It is the responsibility of all employees to report violations or suspected violations in accordance with this Whistleblower Policy.
b. No Retaliation
The Agency will not retaliate against a Whistleblower. This includes, but is not limited to, protection from retaliation in the form of an adverse employment action such as termination, compensation decreases, poor work assignments and threats of physical harm. Any Whistleblower who believes he/she is being retaliated against must contact the Chief of Staff, who has specific and exclusive responsibility to investigate all reported suspected violations. If reporting to the Chief of Staff is inappropriate for a situation, the incident should be reported to the COO.
c. Reporting Violations
The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities. Examples of illegal or dishonest activities are violations of federal, state, or local laws; billing for services not performed or for goods not delivered; and other serious fraudulent financial reporting. If an employee has knowledge of or a concern of illegal or dishonest fraudulent activity, the employee is to contact their immediate supervisor or department director. If the Employee is not comfortable addressing the matter within the Department, the employee can report the concern to the DVP of HR or the CSOO. The employee must exercise sound judgment to avoid baseless allegations. An employee who intentionally files a false report of wrongdoing will be subject to discipline up to and including termination.
d. Compliance Officer
The Chief Executive Officer (OHD) acts as the Compliance Officer and is responsible for investigating and resolving all reported complaints and allegations concerning suspected fraud violations and any reported concerns or complaints regarding corporate accounting practices, internal controls, or auditing and at his/her discretion and shall advise the Executive Committee.
e. Accounting and Auditing Matters
The Executive Committee of the Board of Directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The Coalition Chief Financial Officer shall immediately notify the Executive Committee of any such complaint and work with the committee until the matter is resolved.
f. Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the Code of Ethics. Allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.
g. Confidentiality
If possible, the confidentiality will be maintained. However, the identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide individuals their legal rights of defense. 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.
h. Handling of Reported Violations.
The Executive Director will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.
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