CARPLS Whistleblowing Policy

POLICY: CARPLS requires board members, committee members, employees and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities and to comply with all laws, regulations and ethical rules governing the conduct of CARPLS’ business.  It is the responsibility of all directors, officers and employees to report violations or suspected violations of laws, regulations and internal policies & procedures to CARPLS executive staff and/or officers. All employees, directors and officers of CARPLS will be protected from any disadvantage caused by raising legitimate concerns and shall report suspected illegal activities within the organization.

PROCEDURE: CARPLS encourages its board members, committee members, employees and volunteers to maintain high ethical standards. This whistleblower policy is meant to provide a confidential and effective means for reporting suspected violations of the law. It further serves to protect individuals who report suspected violations from retaliation in any form.

1) Reporting Responsibility:CARPLS seeks to have an “Open Door Policy” and encourages Boardmembers, committee members, employees and volunteers to share their questions, concerns, suggestions or complaintsregarding CARPLS and its operations with someone who can address themproperly. Board and committee members should present their concerns directly to the President of the Board. If a Board member or committee member is notcomfortable speaking with the Board President or is not comfortable with the Board President’sresponse, he or she is encouraged to speak with anyone on the Board. Employees and volunteers should present their concerns directly to his or her immediate supervisor. If the employee or volunteer is notcomfortable speaking with his or her immediate supervisor or is not comfortable with the supervisor’s response, the employee or volunteer is encouraged to speak to the Executive Director. If the matter involves a complaint or concern regarding the Executive Director, the employee or volunteer should speak directly to the Board President. 

2) No Retaliation:   No board member, committee member, or employee who in good faith reports a violation of a law or regulation requirement shall suffer harassment, retaliation or adverseemployment consequences. An employee who retaliates against someone who hasreported a violation in good faith is subject to discipline up to and including terminationof employment. This whistleblowing policy is intended to encourage and enable personsto raise serious concerns within CARPLS prior to seeking resolution outside of CARPLS.

3) Compliance Officer:  CARPLS’s Executive Director, working with the President of the Board, will actas CARPLS’s Compliance Officer. The Compliance Officer is responsible forinvestigating and resolving all employee complaints and allegations concerning violations of laws, regulations and ethical rules governing the conduct of CARPLS’ business. The Board President or his or her designee will take on the Compliance Officer role if the complaint involves the Executive Director. If the complaint involves both the Executive Director and Board President, outside legal counsel will carry out the functions of the Compliance Officer.

4) Accounting and Auditing Matters:  The Finance Committee of the Board of Directors shall address all reportedconcerns or complaints regarding corporate accounting practices, internal controls orauditing. The Compliance Officer shall immediately notify the Finance Committee ofany such complaint and work with the Committee until the matter is resolved.

5) Requirement of Good Faith:  Anyone filing a complaint concerning a violation or suspected violation of the lawor regulation requirements must be acting in good faith and have reasonable grounds forbelieving the information disclosed indicates a violation. Any allegations that prove notto be substantiated and which prove to have been made maliciously or knowingly to befalse will be viewed as a serious disciplinary offense.

6) Confidentiality:   Violations or suspected violations may be submitted on a confidential basis by thecomplainant or may be submitted anonymously. Reports of violations or suspectedviolations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

7) Handling of Reported Violations:  The Compliance Officer, or the person responsible for carrying out theCompliance Officer’s role with respect to a reported or suspected violation, will acknowledge receipt of the reported violation or suspected violation by writing a letter (or e-mail) to the complainant within five (5) business days. All reports will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation. The complainant shall be informed of the results of the investigation and the action to be taken (if any).