The purpose of this policy is to establish a procedure for Forum employees, members and vendors to report illegal or dishonest activity or other misconduct involving The Forum’s financial or business affairs.
Such activity may involve another employee or outside persons or firms doing business with The Forum. Examples of illegal or dishonest activities are violations of federal, state or local laws, billing for services not performed, fraudulent financial reporting or other misconduct involving The Forum’s financial or business affairs.
Employee Reporting Process
If an employee, member or vendor has knowledge of or concern about such illegal or dishonest activity or misconduct, they should communicate with Brian Whalen, President of The Forum.
Communications may be verbal or written. No particular format is necessary. However, all communications should include as much information as possible to permit a thorough and complete evaluation of a complaint or charge. This includes material evidence, names of persons able to corroborate the accusation, if possible, and how to contact the complainant to assure anonymity, if anonymity is desired. The recipient of a complaint is responsible for ensuring that all information regarding the complaint is properly recorded and thus becomes the formal record of the complaint. A copy of any written complaint will be provided to the complainant for confirmation of accuracy. (Note: anonymity or a verbally-registered complaint may hinder the ability of The Forum to investigate the matter in a timely and effective manner.)
Role of the President
All complaints received under this policy will be promptly submitted to the President, who is responsible for overseeing the investigation and coordinating corrective actions. The President will determine the level of investigation the complaint warrants and who the appropriate party is to perform the investigation. He is responsible for determining if the facts support or do not support the complaint. The President will provide a written explanation of the decision to the employee, vendor or member who made the complaint. The President in his discretion may report to The Forum’s outside general counsel complaints received under this policy, their status and their resolution. The President is required to report to the Chair of The Forum’s Board of Directors regarding compliance with this policy.
For a complaint involving the President or senior administrative staff, the Chair of The Forum’s Board of Directors will fill the role of the President and perform the responsibilities identified in the preceding paragraphs and report such a complaint to the Board of Directors.
A person who believes that his/her report of illegal or dishonest activities or other misconduct involving The Forum’s business or financial affairs is not receiving appropriate attention by the President may contact the Chair of the Board of Directors.
An employee (whistleblower) who makes a complaint or charge must exercise sound judgment and act without malice to avoid baseless allegations or frivolous complaints. The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures.
Whistleblower protections are provided in two important areas – confidentiality and against adverse action in the form of retaliation.
Insofar as is reasonably possible, the confidentiality of the whistleblower will be maintained. However, at the discretion of the President or the Chair of the Board of Directors, the whistleblower’s identity may have to be disclosed to conduct a thorough investigation or to comply with applicable laws.
The Forum will not take adverse action against a whistleblower. This includes, but is not limited to, protection from employment action such as termination, compensation decreases, poor work assignments and threats of physical harm. Any whistleblower who believes he/she is being retaliated against should contact the President or, in the case of perceived retaliation by the President, Chair of The Forum’s Board of Directors.
Any employee, however, who knowingly files a false or materially misleading report of illegal or dishonest activities or other misconduct involving The Forum’s business or financial affairs, is subject to disciplinary action.
Employees, members, or vendors with questions regarding this policy should contact the President.