Whistle-Blower Protection Policy

Introduction

FCF is committed to the highest possible standards of ethical, moral, and legal conduct. Like all organizations, ours is faced with risks from dishonesty and fraud. This document aims to communicate our policy regarding the deterrence of dishonesty and fraud within the organization and to provide specific instructions regarding appropriate action in the case of suspected violations. It also aims to provide reassurance that those, who in good faith report suspected violations, will be protected from reprisals or victimization.

Definition of Terms

For purposes of this policy, the definition of dishonesty and fraud includes but is not limited to:

  • Theft or other misappropriation of FCF assets
  • Misstatements or other irregularities in FCF records
  • Misstatements in financial reporting
  • Misuse of FCF resources
  • Illegal activities
  • Forgery or alteration of documents
  • Fraud of any other form

In this document the term employee includes hired staff and members/associates of FCF working in FCF related ministries.

Policy and Responsibilities

Reporting

It is the responsibility of every employee to report concerns relating to suspected dishonesty or fraud. Such concerns shall normally be conveyed to the employee’s immediate supervisor or someone else in management whom the employee is comfortable in approaching. Alternatively, concerns may be communicated directly to the FCF Director. Supervisors are required to report suspected violations reported to them to the FCF Director, who has the responsibility to see that all complaints are investigated.

Additional responsibilities of Supervisors

All employees have a responsibility to report suspected violations. However, those with supervisory and review responsibilities at any level have additional deterrence and detection duties.

  • They are to become aware of things that can go wrong in their area of authority.
  • They are to put into place and maintain effective monitoring, review, and control procedures which will prevent acts of wrongdoing.
  • They are to put into place and maintain effective monitoring, review, and control procedures which will detect acts of wrongdoing promptly should prevention efforts fail.

Timing

The earlier a concern is expressed, the easier it is to take action.

Investigating the Concern

Following the receipt of any complaints submitted, the FCF Director will investigate each matter so reported and recommend corrective and disciplinary actions where appropriate. Investigative or other follow up activity will be carried out in keeping with FCF’s discipline policy and without regard to the suspected individual’s position, level, or relationship with the organization. The FCF Director may enlist FCF Board Members, employees of the ministry and/or outside legal, accounting or other advisors, as appropriate, to conduct any investigation of complaints. In conducting any investigation, the FCF Director shall use reasonable efforts to protect the confidentiality and anonymity of the complainant.

Further Information

The amount of contact between the complainant and the body investigating the concern will depend on the nature of the issue and the clarity of information provided. Further information may be sought from the complainant.

Report to Complainant

The complainant will be given the opportunity to receive follow-up on their concern within two weeks:

  • Acknowledging that the concern was received;
  • Indicating how the matter will be dealt with;
  • Giving an estimate of the time that it will take for a final response;
  • Telling them whether initial inquiries have been made; and
  • Telling them whether further investigations will follow, and if not, why.

Information

Neither the existence nor the results of investigations or other follow up activity will be disclosed or discussed with anyone other than those persons who have a legitimate need to know in order to perform their duties and responsibilities effectively, except that the FCF Director must report to the FCF Board information on complaints received and investigations performed. All inquiries from an attorney or any other contacts from outside the organization, including those from law enforcement agencies or from the person under investigation, should be referred to the FCF Director. Subject to legal constraints, the complainant will receive information about the outcome of any investigations.

Document Retention

The FCF Director shall retain as a part of his records any such complaints or concerns for a period of at least seven years.

Acting in Good Faith

Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates misconduct, dishonesty or fraud. 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 disciplinary offense.

Safeguards

No Retaliation

No director, officer, or employee who in good faith reports a violation shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This policy is intended to encourage and enable employees and others to raise concerns within the organization prior to seeking resolution outside the organization. Additionally, no employee shall be adversely affected because they refuse to carry out a directive which, in fact, constitutes corporate fraud, or is a violation of law.

Confidentiality

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

Anonymous Allegations

Employees are encouraged to put their names to allegations because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified. Concerns expressed anonymously will be investigated, but consideration will be given to:

  • The seriousness of the issue raised;
  • The credibility of the concern; and
  • The likelihood of confirming the allegation from attributable sources.

FCF reserves the right to modify or amend this policy at any time as it may deem necessary.