Mary-Jo Avellar – Provincetown, MA
Trudy Avery – Sandwich, MA
Lisa Cohen, co-Chair – Orleans, MA
Dianne Gauthier – Marstons Mills, MA
Dan Wolf, Chair – Harwich, MA
ASGCC Whistleblower Policy
SECTION I. OVERALL PURPOSE AND STRUCTURE
The AIDS Support Group of Cape Cod (“ASGCC”) requires directors, officers, representatives, staff and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. ASGCC expects directors, officers, representatives, staff and volunteers to operate with honesty and integrity, and in compliance with all applicable laws and regulations, in fulfilling responsibilities.
ASGCC’s Whistleblower Policy is hereby incorporated into the organization’s Code of Conduct and supersedes all prior Whistleblower Policy documents.
SECTION II. NO RETALIATION
It is a violation of the ASGCC Code of Conduct to retaliate against any director, officer, representative, staff member or volunteer 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 ASGCC. Retaliation against someone who has reported a violation in Good Faith (see section 7) is subject to discipline up to and including termination of employment or removal from the board.
SECTION III. OPEN DOOR POLICY
ASGCC has an open-door policy and requests that staff share their employment questions, concerns, suggestions, or complaints with their direct supervisor. If staff are not comfortable speaking with their supervisor or are dissatisfied with their supervisor’s response, they are encouraged to speak with ASGCC’s Compliance Officer and/or ASGCC’s President & Chief Executive Officer.
SECTION IV. REPORTING PROCEDURE
Directors, officers, representatives, staff and volunteers submitting a Whistleblower complaint may do so by reporting the complaint in writing to their supervisor (for staff and volunteers only), or to ASGCC’s Compliance Officer or ASGCC’s President & Chief Executive Officer. Complaints may also be submitted securely via email to [email protected].
The information within the complaint should include date of occurrence, location, people involved, and specifics related to the areas of concern or violations. Available evidence should be presented at the time of the complaint.
Supervisors and managers are required to report Whistleblower complaints conveyed to them, in writing, to ASGCC’s Compliance Officer, who has the responsibility to investigate all reported complaints.
SECTION V. COMPLIANCE OFFICER
ASGCC’s Compliance Officer is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Compliance Officer will advise the President and CEO and the Board of Directors of all complaints and their resolution and will report at least annually to the Audit Committee/Finance Committee on compliance activity relating to accounting or alleged financial improprieties.
SECTION VI. ACCOUNTING AND AUDITING MATTERS
ASGCC’s Compliance Officer shall immediately notify the Audit Committee/Finance Committee of any concerns or complaint regarding corporate accounting practices, internal controls or auditing and work with the committee until the matter is resolved.
SECTION VII. 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.
Filing a whistleblower complaint about an internal employment matter that is not an ethics violation, or a suspected violation of law, or a complaint of discrimination, suspected fraud, or is a suspected violation of any regulation governing the operations of ASGCC is a violation of the agency’s Code of Conduct.
SECTION VIII. CONFIDENTIALITY
Concerns or complaints 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.
SECTION IX. HANDLING OF REPORTED VIOLATIONS
ASGCC’s Compliance Officer 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.
Compliance Officer (Effective Date: March 23, 2022)
Jean DeMichele, SHRM-SCP, SPHR
AIDS Support Group of Cape Cod
Policy approved by the Board of Directors on December 22, 2021.