CASC Whistleblower Protection Policy

CASC requires its executive officers, member organizations and their representatives, employees, non-member participants, and contractors (“CASC Community”) to observe high standards of business and personal ethics including complying with the Code of Conduct while conducting their duties and responsibilities. As representatives of CASC, the CASC Community must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility

This Whistleblower Policy is intended to encourage the CASC Community and others to raise serious concerns internally so that CASC can address and correct inappropriate conduct and actions. It is the responsibility of each individual of the CASC Community to report concerns about violations of CASC’s policies and procedures or suspected violations of applicable law or regulations that govern CASC’s operations.

No Retaliation

It is contrary to the values of CASC for anyone to retaliate against any person who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of CASC.

A CASC Community member who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including removal from association with CASC, including, but not limited to termination of employment, membership, contractor status as applicable.

Reporting Procedure

CASC has an open door policy and suggests that CASC Community members share their questions, concerns, suggestions or complaints with the CASC Executive Committee. If you are not comfortable speaking with the Chair or you are not satisfied with the Chair’s response, you are encouraged to speak with the Vice Chair.  Members and the Executive Committee are required to report complaints or concerns about suspected ethical and legal violations in writing to CASC’s Chair, who has the responsibility to investigate all reported complaints and ensure that all complaints about unethical or illegal conduct are investigated and resolved. The Chair will advise the [Executive Committee and/or the Membership] of all complaints and their resolution and will report at least annually to the [finance committee/Treasurer etc] on compliance activity relating to accounting or alleged financial improprieties.

Accounting and Auditing Matters

CASC’s Chair shall immediately notify the [Audit Committee/Finance Committee/Treasurer] of any concerns or complaints regarding corporate accounting practices, internal controls or auditing and work with [the committee] until the matter is resolved.

Acting in Good Faith

Anyone filing a written 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. Any 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.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

CASC’s Chair will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

 

Policy approved by the [Executive Committee] on {Date}.

_____________________________

 

[Secretary’s Name], Secretary

 

Date: ________________