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52 HB Fiscal Polices&Procedures <br /> Section - • • <br /> A. Overview <br /> This section outlines clear procedures for handling whistleblower complaints. The Sarbanes-Oxley <br /> Act of 2002, Section 1107, Retaliation Against Informants states that it is illegal to retaliate <br /> against a whistleblower. Proper handling of complaints will help protect HB from being accused of <br /> retaliation against whistleblowers. To be effective, this policy must be circulated to all employees <br /> and board members. <br /> This policy establishes procedures for the receipt and treatment of employee complaints regarding <br /> wrongful conduct relating to HB. The policy has been adopted to: <br /> 1. Provide employees with a confidential mechanism to alert management of alleged <br /> Wrongful Conduct (as defined below). The Finance Committee determines the <br /> confidential mechanism and shall outline it in the Employee Handbook. <br /> 2. Ensure that all information regarding such conduct is handled in a professional and <br /> thorough manner. <br /> 3. Protect employees from retaliation for bringing such concerns to the attention of <br /> management. <br /> Definition of .. • <br /> STANDARDS DEFINITION <br /> HB requires employees to observe the highest standards of business and personal <br /> Standards for ethics in the conduct of their duties and responsibilities. Employees must <br /> Employee Conduct practice honesty and integrity in fulfilling their job responsibilities and must <br /> comply with all applicable laws, government regulations and agency rules and <br /> procedures. <br /> Deflnitions of Wrongful Conduct <br /> CONDUCT • <br /> Baseless Allegations Claims or accusations made with reckless disregard for their truth or falsity. <br /> A deliberate act or failure to act with the intention of obtaining an unauthorized <br /> benefit. Examples: <br /> • Forgery or alteration of documents <br /> • Unauthorized alteration or manipulation of computer files <br /> • Fraudulent financial reporting <br /> Fraudulent or Dishonest • Pursuit of a benefit or advantage in violation of the Institute's conflict of <br /> Conduct interest policy <br /> • Misappropriation, misuse, or theft of Institute resources, such as funds, <br /> supplies, or other assets <br /> • Authorizing or receiving compensation for goods not received or services <br /> not performed <br /> • Authorizing or receiving compensation for hours not worked <br /> Examples of other wrongful conduct include: <br /> Other Wrongful • Criminal behavior <br /> Conduct • Inappropriate behavior towards a coworker <br /> • Other violations of agency olicies or applicable laws <br /> Last updated September 2022] <br />