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53 HB Fiscal Polices&Procedures <br /> B..Policy <br /> 1. Reporting Responsibility <br /> Each employee is responsible for complying with the above standards, and for reporting wrongful <br /> conduct or suspected wrongful conduct by other employees. Wrongful conduct includes, but is not <br /> limited to, fraud, theft, embezzlement, mishandling of funds, criminal behavior, questionable <br /> accounting or auditing practices, inappropriate behavior towards a client or other violations of <br /> agency policies or applicable laws. <br /> 2. Non-Retaliation <br /> No employee shall suffer harassment, retaliation, or any other adverse employment consequence <br /> as a result of: <br /> • Reporting suspected wrongful conduct in accordance with the procedures of this policy; <br /> • Providing information, causing information to be provided or otherwise assisting in any <br /> investigation, including investigations by local, state, or federal governmental bodies, <br /> regarding any wrongful conduct; or <br /> • Filing, causing to be filed, testifying, or otherwise assisting in a criminal, civil or <br /> regulatory investigation or proceeding relating to HB. <br /> Employees seeking retaliation against someone who accounts for a violation in good faith shall be <br /> subject to discipline including potential termination. By encouraging and enabling employees and <br /> others to raise serious concerns within HB, the Whistleblower Policy hopes to initially address the <br /> situation internally. <br /> 3. Reporting Violations <br /> This Whistleblower Policy encourages employees to share their questions, concerns, suggestions, <br /> or complaints about other employees' conduct with someone who can address them properly. In <br /> most cases, an employee's primary supervisor is in the best position to address an area of <br /> concern. However, an employee who is not comfortable speaking with his/her supervisor or is not <br /> satisfied with the supervisor's response is encouraged to speak with his/her Department Head. <br /> Senior managers are required to report suspected violations to HB's Compliance Officer and/or <br /> HB's General Counsel, who has specific and exclusive responsibility to investigate all reported <br /> violations. An employee who is not satisfied or is uncomfortable with speaking to staff members in <br /> their department should contact HB's Compliance Officer directly. <br /> 4. Compliance Officer <br /> This role is played by the Finance Committee Chair. The Compliance Officer is responsible for <br /> investigating and resolving all reported complaints and allegations concerning violations and, at <br /> his or her discretion, shall advise HB's Chair of the Board of Directors if the complaint concerns an <br /> alleged violation by the organization President. The Compliance Officer shall have direct access to <br /> the Board of Directors and shall report to the Board of Directors at least annually on <br /> compliance/whistleblower activity. <br /> 5. Accounting and Auditing Matters <br /> The Executive Director shall immediately notify the Chair of the Board of Directors and the <br /> Treasurer of the Board of any reported concerns or complaints regarding HB's finances, including <br /> accounting practices, internal controls, alleged malfeasance or illegal conduct, or auditing issues. <br /> After immediately notifying the Board of Directors of any such grievance, the Compliance Officer, <br /> Last updated September 2022 <br />