ISSUE RESOLUTION POLICY
1. Purpose
This Policy is intended to establish the expectation and conditions for unethical, illegal, or fraudulent conduct to be reported and addressed.
United Way of Kingston, Frontenac, Lennox & Addington (UWKFLA) is committed to ensuring the organization acts in accordance with applicable laws and observes the highest standards of business and personal ethics in the conduct of its responsibilities. This Policy sets out the duty of all Board Directors, other volunteers, sponsored employees, and employees to report misconduct or suspected misconduct, including fraud and financial impropriety, and ensures that anyone who makes a report in good faith will be protected from reprisal.
2. Scope
This Policy applies to all Board Members, other volunteers, sponsored employees and employees.
3. Policy
Duty to Report Misconduct
It is the duty of all Board Members, other volunteers, sponsored employees, and employees to report misconduct or suspected misconduct, including fraud and financial impropriety, to the Board of Directors. Such prohibited misconduct may include, but is not limited to:
• Providing false or misleading information, or withholding material information on UWKFLA’s financial statements, tax returns or other public documents;
• Pursuit of material benefit or advantage in violation of UWKFLA’s Conflict of Interest Policy;
• Misappropriation or misuse of UWKFLA resources such as funds or assets; or
• Unauthorized alteration or manipulation of electronic or physical records.
No Reprisal
UWKFLA will not take reprisal in any way against anyone who files a complaint in good faith or who acts as a witness or otherwise participates in the investigation of a complaint. UWKFLA also prohibits reprisal by anyone against another employee who files a report in good faith or who acts as a witness or otherwise participates in an investigation. Any employee who is found to have engaged in reprisal against a person for seeking assistance through this Policy, or for filing a report in good faith, may be subject to discipline, up to and including termination. UWKFLA will also take appropriate action in relation to any Board Member, volunteer, sponsored employee, or employee who is found to have engaged in reprisal in violation of this Policy.
Reprisal Includes
a) Any adverse action or consequence that occurs because an individual has filed a report or provided information about an incident of misconduct;
b) Intentionally pressuring anyone who is covered by this Policy to ignore or not report an incident of misconduct; or
c) Intentionally pressuring anyone who is covered by this Policy to lie or provide less than full cooperation with an investigation of a complaint of an incident of misconduct
An employee who makes a false complaint or otherwise abuses this process may be subject to discipline up to, and including, termination of employment. Such discipline is not a reprisal or breach of this policy. UWKFLA will also take appropriate action in relation to any Board Member, volunteer, sponsored employee, or employee who makes a false complaint or otherwise abuses this process.
4. Procedures
Compliance Officer
UWKFLA’s Compliance Officer for the purpose of this Policy is the President & Chief Executive Officer (CEO). The Compliance Officer is responsible for determining the review or investigation procedure after consultation with all stakeholders and resolving all reported complaints and allegations concerning misconduct and is required to report to the Board of Directors on all misconduct complaints.
The role of the Compliance Officer with respect to protection against reprisal is to receive reports of reprisals; to keep a confidential record of all reports received; to inform the Board of Directors of the reports; and to initiate a review normally within thirty (30) business days of receiving the report.
Reporting of Misconduct
Option 1
An employee should report any suspected misconduct directly to their supervisor. Supervisors are required to report all suspected misconduct they receive from their staff in writing to UWKFLA’s Compliance Officer or the Chair of the Board. All such complaints will be kept confidential to the degree possible, and information will be shared strictly on a need-to-know basis.
Option 2
If the employee or volunteer is not comfortable speaking with their supervisor, the individual may approach the Compliance Officer to report such cases. The employee or volunteer can also submit suspected misconduct anonymously through the following methods:
Website: https://app.alias-solution.com/contact/en/uwc01
Telephone: 1-833-809-1001
The anonymous reporting tool (Alias) will follow the following reporting structure in the event of an anonymous report being logged within their system:
Who the Report Targets Alias will Notify
President & CEO (Compliance Officer) Chair or Vice Chair of the Board
Director of Administration President & CEO
Any Other Person Director of Administration
The Compliance Officer, Chair of the Board, or Director of Administration will respond to the complainant (when known) to acknowledge receipt of the reported misconduct normally within ten (10) business days and initiate a review normally within thirty (30) business days of receiving the report to determine whether an investigation is required. The format of a review or investigation may vary, depending on the nature and particular circumstances of each report. All reports will be reviewed or investigated, and findings will be presented to the Compliance Officer or Chair of the Board normally within sixty (60) business days except for extenuating circumstances. In cases where an extension is required by the Compliance Officer or Chair of the Board, the United Way Board of Directors or Chair of the Board will be advised of the reasons for this extension. Appropriate action will be taken at the completion of the review or investigation. The Board of Directors will be informed of all such complaints and their disposition.
Reporting of Reprisal
Individuals who believe that reprisal action has been taken against them because they have reported misconduct should forward all information and documentation to support their complaint to the Compliance Officer, or directly to the Chair of the Board depending on the circumstance. Reports of retaliation will be kept confidential to the extent possible, consistent with the need to conduct an adequate review or investigation.
If the result of the review or investigation indicates there is a credible case of reprisal or threat of reprisal, it will refer the findings to the Board and recommend measures to safeguard the interests of the complainant. The Compliance Officer may recommend appropriate disciplinary or other actions to be taken against the person(s) who committed the act of reprisal. The Board will make a decision on the appropriate action to be taken.
If the investigation reveals no credible case of reprisal or threat of reprisal, the complainant will be advised of other informal mechanisms on conflict resolution. Regardless of outcome, the complainant will receive the outcome of the investigation in a format based on their preference from the Compliance Officer. The Board will be informed of the outcome.
Appeal Procedure
Should the complainant not be satisfied with the findings of the Compliance Officer, they may make a direct appeal to the Chair of Board of Directors within twenty (20) business days of the receipt of the written report. Ruling from the Board will constitute the final internal disposition of the complaint.