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COA WHISTLE BLOWER POLICY


The Council on Aging of Etowah County, Inc.

Whistle Blower Policy



The Council on Aging of Etowah County, Inc. is committed to operating in the furtherance of it tax-exempt purposes and in compliance with all applicable laws, rules and regulations, including those concerning accounting and auditing, and prohibits fraudulent practices by any of its board members, officers, employees, or volunteers.  This policy outlines a procedure for employees to report actions that an employee reasonably believes violates a law, or regulation or that constitutes fraudulent accounting or other practices.  This policy applies to any matter which is related to The Council on Aging of Etowah County, Inc. business and does not relate to private acts of an individual not connected to the business of The Council on Aging of Etowah County, Inc.

If an employee, volunteer, bookkeeper or board member has reasonable belief that an employee, volunteer, bookkeeper, or board member of The Council on Aging of Etowah County, Inc. has engaged in any action that violates any applicable law, or regulation, including those concerning accounting and auditing, or constitutes a fraudulent practice, the employee, volunteers, bookkeeper or board member is expected to immediately report such information to the Executive Director.  If the employee, volunteer, bookkeeper, or board member does not feel comfortable reporting the information to the Executive Director, he or she is expected to report the information to a member of the Board or Executive Board such as; Board Chair, Vice Chair, Treasurer or Secretary.  If the employee, volunteer, bookkeeper, or board member does not feel comfortable reporting the information to the Board or Executive Board, he or she is expected to report it to the Director of United Way.

All Reports will be followed up promptly, and an investigation conducted.  In conducting its investigation, The Council on Aging of Etowah County, Inc. will strive to keep the identity of the complaining individual as confidential as possible, while conducting an adequate review and investigation.

The Council on Aging of Etowah County, Inc. will note retaliate against an employee in the terms and conditions of employment because that employee:  (a) reports to the Executive Director, the Board of Directors, or to a federal, state or local agency what the employee believes in good faith to be a violation of the law; or (b) participates in good faith in any resulting investigation or proceeding, or (c) exercises his or her rights under any state or federal law(s) or regulation(s) to pursue a claim or take legal action to protect the employee’s rights.

The Council of Aging of Etowah County, Inc., may take disciplinary action (up to and including termination) against an employee who in management’s assessment has engaged in retaliator conduct in violation of this policy.

In addition, The Council on Aging of Etowah County, Inc. will not, with the intent to retaliate, take any action harmful to any employee who has provided to law enforcement personnel or a court truthful information relating to the commission or possible commission by The Council on Aging of Etowah County, Inc. or any of its employees of a violation of any applicable law or regulation.

Staff will be trained on this policy and The Council on Aging of Etowah County, Inc. prohibition against retaliation in accordance with this policy.

Illustrative Types of Concerns

·         The following is a non-exhaustive list of the kinds of improprieties that should be reported:

·         Supplying false or misleading information on The Council on Aging of Etowah County, Inc. financial or other public documents, including its Form 990EZ

·         Providing false information to or withholding material information from The Council on Aging of Etowah County, Inc. board or auditors

·         Destroying, altering, mutilating, concealing, covering up, falsifying, or making a false entry in any records that may be connected to an official proceeding, in violations of federal or state law or regulations

·         Altering, destroying, or concealing a document, or attempting to do so, with the interest to impair the documents availability for use in an official proceeding or otherwise obstructing, influencing, or impeding any official proceeding, in violation of federal or state law or regulations

·         Embezzling, self-dealing, private inurnment (i.e., The Council on Aging of Etowah County earnings inuring to the benefit of a director, or officer) and private benefit (i.e., The Council on Aging of Etowah County, Inc. assets being used by anyone in the organization for personal gain or benefit)

·         Paying for services or goods that are not rendered or delivered

·         Using remarks or actions of a sexual nature that are not welcome and likely to be viewed as personally offensive, including sexual flirtations; unwelcome physical or verbal advances; sexual propositions; verbal abuse of a sexual nature; the display a sexually suggestive objects, cartoons, or pictures; and physical contact of a sexual or particularly personal nature

·         Using epithets, slurs, negative stereotyping, and threatening, intimidating, or hostile acts that relate to race, color, religion, gender, national origin, age, or disability

·         Circulating or posting written or graphic material in the workplace that denigrates or shows hostility or aversion toward an individual or group because of race, color, religion, gender, nationality, age, or disability.

·         Discriminating against an employee or potential employee due to a person’s race, color, religion, sex, sexual orientation, national origin, age, physical or mental impairment, or veteran status

·         Violating The Council on Aging of Etowah County, Inc., Code of Ethics, Conflict-of-Interest Policy, Organization Policies or Equal Employment Opportunity Policy.

·         Facilitating or concealing any of the above or similar actions





This Document was approved by the COA Board of Directors on July 15, 2015

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