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Whistle Blower Policy
Casa de Esperanza de los Ninos, Inc.

Complaint Procedure for Potential Violations of Casa’s Code of Ethics and Laws and Regulations governing Casa’s Operations
Casa de Esperanza de los Ninos, Inc. (“Casa”) requires Governing Board members, administrators and employees to observe high standards of business and ethics in the conduct of their duties and responsibilities and to comply with all applicable laws and regulations.

Reporting Responsibility: This Complaint Procedure is intended to encourage and enable employees and others to raise concerns internally so that Casa can address and correct inappropriate conduct and actions. It is the responsibility of all Governing Board members, administrators, employees and volunteers to report concerns about potential violations of Casa’s Code of Ethics or any laws or regulations that govern Casa’s operations.

No Retaliation: Casa prohibits retaliation against any Governing Board member, administrator, employee or volunteer because of a good faith report of a potential violation of Casa’s Code of Ethics or any laws or regulations that govern Casa’s operations. An individual who retaliates against someone because that person has reported a potential violation in good faith may be subject to disciplinary action, up to and including, termination of employment or termination of the business relationship with Casa.

Reporting Procedure: Casa has an open-door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. If the employee is not comfortable speaking with the employee’s supervisor or is not satisfied with the supervisor’s response, the employee should speak with the Executive Director.  Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or the Executive Director.
In the event Casa’s Executive Director is a part of the complaint or concern, the employee should report the matter directly to the President of the Casa de Esperanza Governing Board.
Supervisors and managers are required to report complaints or concerns about potential ethical and legal violations in writing to Casa’s Executive Director, who has the responsibility to investigate all reported complaints.

Compliance Officer:  The Executive Director serves as the Compliance Officer.  Casa’s Compliance Officer is responsible for ensuring that all complaints about potential unethical or illegal conduct are investigated and resolved. The Compliance Officer will advise the Governing Board of all complaints and their resolution and will report at least annually to the Treasurer and Chair of the Finance and Administration Committee on compliance activity relating to accounting or alleged financial improprieties.

Accounting and Auditing Matters: Casa’s Executive Director shall immediately notify the Finance and Administration Committee of any concerns or complaint regarding corporate accounting practices, internal controls or auditing and work with the committee until the matter is resolved.

Acting in Good Faith: Anyone filing a written complaint concerning a violation or potential violation must act in good faith and have reasonable grounds for believing the information disclosed indicates a violation.

Confidentiality: Violations or potential violations may be submitted on a confidential basis by any individual. Reports of violations or potential violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations: Casa’s Executive Director will notify the person who submitted a complaint and acknowledge receipt of the reported violation or potential violation. All reports will be promptly investigated and appropriate action will be taken if warranted by the investigation.

Compliance Officer:  The Executive Director or a third party designated by the organization to receive, investigate and respond to complaints.
 
Shelley M. Starr
Executive Director
 
Policy Approved by the Governing Board on December 7, 2017