Whistleblower Policy
WHISTLEBLOWER POLICY
ICSO H&W
1. Purpose.
ICSO H&W requires Named Fiduciaries, committee members and staff (hired or contracted) to observe high standards of business and personal ethics in the conduct of their duties and responsibilities, and all Named Fiduciaries, committee members, and staff to comply with all applicable laws and regulatory requirements.
2. Reporting Responsibility.
ICSO H&W seeks to have an “Open Door Policy” and anyone (a “reporting person”) to share their questions, concerns, suggestions or complaints (“issues”) regarding the ICSO H&W and its operations with someone who can address them properly. In most cases, a reporting person should present such issues to the Chairman of the Named Fiduciaries or the Secretary. TheSecretary is generally in the best position to address any reported issue. However, if a reporting person is not comfortable speaking with the Chairman or is not comfortable with the Chairman’s response, or is not comfortable speaking with the Secretary or is not satisfied with theSecretary’s response, the reporting person is encouraged to speak with any of the NamedFiduciaries whom the person is comfortable in approaching, whose contact information can be obtained from the Secretary at any time.
3. No Retaliation.
No person who in good faith reports a violation of a law or regulation requirement shall suffer harassment, retaliation or adverse employment consequence. Any person who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination or removal from ICSO H&W staff, membership or position/service. ThisWhistleblower Policy is intended to encourage and enable persons to raise issues within ICSOH&W prior to seeking resolution outside of ICSO H&W.
4. Compliance Officer.
ICSO H&W’s Secretary, working with the Chairman of the Named Fiduciaries, will act as ICSOH&W’s Compliance Officer. The Compliance Officer is responsible for investigating and resolving all issues reported under this policy. The Chairman or his or her designee will take on the Compliance Officer role if a complaint involves the Secretary. If a complaint involves both the Secretary and the Chairman, another Named Fiduciary appointed by the Named Fiduciaries will carry out the functions of the Compliance Officer.
5. Accounting and Auditing Matters.
The Named Fiduciaries shall address all reported issues regarding corporate accounting practices, internal controls or auditing. The Compliance Officer shall immediately notify theNamed Fiduciaries of any such issue and work with the Named Fiduciaries until the matter is resolved.
6. Requirement of Good Faith.
Any reported issue concerning a violation or suspected violation of any law 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 offense.
7. Confidentiality.
Violations or suspected violations of the law may be submitted on a confidential basis by the complainant or may be submitted confidentially. Reports of such violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation or comply with legal requirements.
8. Handling of Reported Violations.
The Compliance Officer, or the person responsible for carrying out the Compliance Officer’s role with respect to a reported or suspected violation of the law, will acknowledge receipt of the reported violation or suspected violation by writing a letter (or e-mail) to the complainant within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.To submit a confidential report, mail
To submit a confidential report, mail to:
ICSO H&W
Attention: Gregg Dykstra
3601 Vincennes Road
Indianapolis, IN 46268
Or email: gdykstra@namic.org
