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The purpose of this Whistleblower Policy is to provide direction to all current and former employees, volunteers and Board members regarding the communication of events/occurrences or concerns, with respect to issues of integrity and honesty and, in particular, of questionable financial or operational matters.
The Canadian Hearing Society (CHS) is committed to conducting itself with honesty and integrity at all times. If, at any time, this commitment is not followed or appears in doubt, CHS will seek to identify and remedy such situations. Accordingly, it is the Policy of CHS to ensure that when an employee, volunteer or board member has reasonable grounds to believe that another CHS employee, volunteer or board member has committed, or is about to commit, a financial or other wrongdoing:
a) The employee, volunteer or board member may disclose this information through the process that commences on Page 2 of this Policy;
b) The matter will be reviewed and if warranted, investigated by the designated individual/Officer;
c) The employee, volunteer or board member will be protected from reprisals;
d) The subject of the disclosure will be provided with an opportunity to respond to the allegations;
e) All parties to an investigation will be treated fairly and equitability;
f) Confidentiality will be maintained to the greatest extent possible;
g) If wrongdoing is found, appropriate remedial and disciplinary actions will be taken.
This Policy is in accordance with Federal and Provincial Legislation and is located on the CHS Website under Compliments and Complaints
DEFINITION – REASONABLE GROUNDS OF A “WHISTLEBLOWER EVENT”
For the purposes of this Policy and as defined by Federal and Provincial legislation, a Whistleblower event is triggered if any one of the following incidents occur:
a) A contravention of any Act of Parliament or of the legislature of a Province;
b) A misuse of public funds or public assets;
c) A gross mismanagement or omission or neglect of duty;
d) An abuse of authority;
e) An act or omission that creates a substantial and specific danger to the life, health or safety of persons, or to the environment;
f) A serious breach of CHS Code of Conduct;
g) Breach of fiduciary duty and/or abuse of trust;
h) Inappropriate occurrences at an Agency event;
i) Knowingly directing a person to commit a wrongdoing set out above; or
j) Concealment of any of the above or any other breach of this policy.
PROCESS FOR BRINGING FORWARD A WHISTLEBLOWING EVENT/OCCURRENCE OR CONCERN
1. Dependent on the employee/volunteer/Board member involved in the financial or other wrongdoing, a written statement, or ASL translated statement, must be submitted to the following individuals:
a) If the wrongdoing is with respect to any CHS employee or volunteer or party acting on behalf of CHS, the statement must be submitted to the President and CEO with a copy sent to the Vice-President, Human Resources.
b) If the wrongdoing is with respect to a member of the Senior Management Team, the statement must be submitted to the President and CEO.
c) If the wrongdoing is with respect to the President and CEO, the statement must be submitted to the Chair of the Board and a copy sent to the Governance Committee.
d) If the wrongdoing is with respect to a member or members of the Board, the statement is to be submitted to the Chair of the Board.
f) If the wrongdoing is with respect to the Chair of the Board, the statement must be submitted to the Vice-chair(s) of the Board.
The Chart below summarizes to which office or person a wrongdoing should be submitted to:
WRONGDOING WITH RESPECT TO:
SUBMISSION TO BE SENT TO:
Any CHS Employee, Volunteer or other Party acting on CHS behalf
President and CEO and a copy to the Vice-President, Human Resources
Member of the Senior Management Team
President and CEO
President and CEO
Chair of Board of Directors and a copy to the Governance Committee
Member of Board of Directors
Chair of Board of Directors
Chair of Board of Directors
Vice-chair(s) of Board of Directors
2. The Whistleblower must immediately communicate the Whistleblower occurrence/event or concern as soon as the Whistleblower becomes aware of such situations. The occurrence/event or concern shall be addressed in written or ASL translated format and sent to the appropriate individual/group described above.
3. The Whistleblower will not be discharged, demoted, suspended, threatened, harassed, or in any other manner discriminated against as a result of communicating a genuine Whistleblower occurrence/event or concern. Any CHS employee found to be in violation of this policy (i.e. continued harassment of the Whistleblower) may be subject to termination of employment. Similarly, any volunteer or Board member found to be in violation of this policy may have their relationship with CHS terminated.
4. An individual is not required to prove the truth of an allegation, but he/she is required to act in good faith. Any individual who does not act in good faith in reporting a suspected violation may be subject to disciplinary action up to and including termination of employment or relationship with CHS.
5. All reported Whistleblower occurrences/events or concerns will be treated as confidential and sensitive. In addition, the Whistleblower shall be provided the opportunity to remain anonymous, save and except in those circumstances where the nature of the disclosure and/or the resultant investigation make it necessary to disclose identify (for example, legal investigations or proceedings). In such cases, all reasonable steps shall be taken to protect the Whistleblower from harm as a result of having made a disclosure.
6. CHS cannot act on anonymous reporting as proper investigation may prove impossible without the opportunity to substantiate allegations by obtaining further facts and information and confirming good faith.
Once a Whistleblowing event/occurrence or concern is brought forward to the appropriate individual/Officer an investigation will commence. The designated individual/Officer may enlist the assistance of one or more employees and outside legal, accounting or other advisors, as may be appropriate to conduct the investigation.
A report will be prepared by the designated individual/Officer and any legal or other action will be taken as appropriate.
Each Whistleblower occurrence/event or concern will be treated as confidentially as possible and with due care. The results of the Whistleblowing event/occurrence or concern investigation will be shared with the Whistleblower. This will not include details of any disciplinary action, which will remain confidential to the individual concerned.
This Policy applies to all current and former employees, volunteers and Board members of CHS.
APPROVED BY: CHS BOARD OF DIRECTORS
Sept. 27, 2014
SIGNED BY: CHS Chair, Board of Directors
Sept. 28, 2014