Policies

Whistleblower Policy

Policy Objective

Crohn’s and Colitis Canada is committed to the highest standards of business and ethical conduct and values openness and transparency. The purpose of this policy is to encourage and enable the reporting of alleged or potential wrongdoings in accordance with applicable laws, ethical behaviours and/or business conduct. 

This policy sets out the duty of all Directors, Board Committee members (Board), employees, and volunteers to report misconduct or suspected misconduct including fraud or financial impropriety and ensures that anyone who makes a report in good faith will be protected from retaliation.

Policy Application

This policy direction applies to all directors, board committee members, employees, and volunteers.

Policy Details

Duty to Report Misconduct

It is the duty of the directors, board committee members, employees, or volunteers to report misconduct as soon as they become aware of the alleged misconduct.  This includes misconducts such as, but not limited to:

• Endangerment of health and safety
• Abuse of authority
• Any matters relating to the external audit of financial statements including false or misleading information, withholding material information relating to financial statements, tax returns, or other public documents.
• Misappropriation or misuse of Crohn’s and Colitis Canada resources such as funds or assets
• Pursuit of material benefit or advantage for personal gain; or
• Unauthorized alteration or manipulation of electronic records.

Reporting Misconduct

It is the duty of individuals to report their concern as soon as they become aware of the alleged violation. Concerns should be reported to the President and Chief Executive Officer (CEO), unless the concern is about the CEO or a board director, in which the concern should be reported to the Chair of the board.  If the concern is about the chair of the board, it should be reported to the Vice Chair of the board. 

In matters involving the CEO, the misconduct should be reported directly to the board chair for investigation and the board chair will assign a designate to oversee the investigation.

Reports are to be documented by the receiver/complainant in writing containing as much detail as possible to facilitate investigation.  

Handling of Reports, and Investigation

The CEO (or designate) for the purpose of this policy, is accountable for overseeing the investigation and ensuring that all reported complaints and allegations concerning misconduct are resolved and reported to the board.  

All information is to be kept confidential, and information is to be shared strictly on a need-to-know basis.

Timelines

All reports will be promptly investigated, and appropriate corrective action will be taken if warranted.

No Retaliation

Individuals should feel confident when reporting violations or when assisting in investigations of such alleged violations.  Crohn’s and Colitis Canada will not tolerate retaliation or discrimination of any kind against anyone who makes a good faith complaint or assists in an investigation under this policy. 

Reporting of Reprisal

Individuals who believe that reprisal action has been taken due to a reported misconduct should forward all supporting information to the CEO or direct to the chair of the board, depending on the circumstances.  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 that there is a credible case of reprisal or threat of reprisal, the CEO/designate will refer the findings to the board with recommended measures to safeguard the interest of the complainant. The CEO/designate may also recommend disciplinary action against the person(s) who committed the act of reprisal, and the board will then make the decision on the appropriate action to be taken.

Should the investigations find no credible case of reprisal or threat of reprisal, the complainant and Board will be advised of the outcome in writing from the CEO/designate.

Monitoring and Compliance

Related Policies, Legislation 

Other Crohn’s and Colitis policies that complement and support this policy direction include but are not limited to: 

• Resolving Community Member’s Concerns 
• Privacy
• Respect in the Workplace; and  
• Code of Conduct. 

Definitions