Board Policy For Raising Concerns Including Financial Stewardship
Policy Management Responsibility
Chief Financial Officer
Oversight by the Finance and Audit Committee
Approval by Board
Purpose & Scope
This policy is focused on the need to maintain integrity in the financial affairs, controls and reporting of the UWCA. The leading role that UWCA plays in society demands that it maintain a scrupulous commitment to ethical practices and good management. Accordingly, it requires all persons working with the UWCA, in whatever capacity, to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. All such persons must practice honesty and integrity in fulfilling their responsibilities and strive to comply with all applicable laws and regulations.
While this policy is aimed at reporting possible errors, omissions or fraud relating to financial matters, concerned parties may, if they have not gained satisfaction in reporting other similar issues, avail themselves of this policy.
This policy aims to provide an avenue for Associates to confidentially or anonymously raise concerns in good faith, with the assurance that they will be protected from reprisals or victimization.
The Committee has a responsibility to endeavour to ensure that UWCA responds appropriately to complaints that allege:
- improper usage of the organization’s assets and resources through fraudulent or dishonest conduct;
- inappropriate actions and relationships that could reduce the effectiveness of financial controls;
- illegal, unethical or questionable practices that adversely affect, or may adversely affect, the financial assets of the UWCA.
The procedures in this Policy are designed to ensure that reported issues are investigated, and result in action appropriate to each case, including the possibility of censure, and civil or criminal procedures.
This policy applies to all UWCA Associates.
Anonymous means unknown authorship, and without designation that might lead to information about the authorship. Anonymity is not compromised by assignment of a code or other designation with which a person can communicate, without revealing his or her identity.
Associate means full-time or part-time staff, temporary staff, contractual worker, or volunteer of UWCA.
Baseless Allegations means allegations made with disregard for their truth or falsity and for which there is little or no evidence to support them.
Committee means the Finance and Audit Committee of the UWCA.
Complaint means any adverse information as contemplated above, provided to the Finance and Audit Committee as envisaged in this policy.
Confidential means authorized for access by only those persons who have a need to know. Ordinarily, a need to know arises from an obligation to investigate or to take remedial or disciplinary action.
Executive Team means the President and CEO; The Vice President and COO; The Chief Financial Officer; The Vice President of Campaign and Resource Development; the Vice President of Community Investments and Collaboration, the Vice President of Marketing and Communications and the Vice President of Investor Relations.
Fraudulent or Dishonest Conduct means a deliberate act or failure to act and includes the following examples:
- Forgery or alteration of documents
- Unauthorized alteration or manipulation of computer files
- Fraudulent or deliberately deceptive financial reporting
- Pursuit of a benefit or advantage in violation of UWCA’s conflict of interest policy
- Misappropriation or misuse of UWCA resources, such as funds, supplies, or other assets
- Authorizing or paying compensation for goods or services not received
- Authorizing or receiving compensation for hours not worked.
Submitter means a person who complains, including a member of the public or an Associate, who informs a Supervisor, member of the Executive Team, or Chair of the Committee about an activity which that person believes to be fraudulent, dishonest or unethical in terms of this policy.
Supervisor means the person the Associate directly reports to.
UWCA means United Way of Calgary and Area
The Submitter is to send a copy of the complaint to the Chair of the Committee or the Chair of the Board.
Submitters reporting a violation should note the following:
- All mail enclosing a complaint should be marked “Private and Confidential”;
- Timely reporting is essential. The earlier a concern is expressed, the easier it may be to take action;
- Although the Submitter is not expected to prove the truth of an allegation, they need to be in a position to demonstrate that there are sufficient grounds for concern.
Associates are encouraged to report violations or suspected violations to their Supervisors, or a member of the Executive Team, in accordance with this Policy.
Submitters will need to decide on the degree of anonymity they desire, before electing which means of communication they wish to employ.
Submitters are encouraged to provide, but are not required to provide, the following information:
- telephone number
- email address
- mail address
The Supervisor or Executive Team member shall investigate the complaint as soon as reasonably possible. On concluding the investigation, the following actions shall be taken:
|Person to whom reported||Action to be taken by person to whom reported|
|Supervisor, not on Executive Team|| |
|Member of Executive Team|| |
|Chair of the Committee|| |
No Submitter, who in good faith makes a complaint, shall suffer harassment, retaliation or adverse employment consequence. An Associate who retaliates against a Submitter is subject to discipline, up to and including termination of employment, work, or volunteer contract. This Policy is intended to encourage and enable Associates to raise concerns and see them satisfactorily dealt with within UWCA.
All reports will be treated seriously. UWCA, unless required otherwise by law, will keep the Submitter’s identity confidential.
The policy encourages Submitters to put their names to complaints 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 apparent:
- seriousness of the issue raised;
- credibility of the concern; and
- likelihood of confirming the allegation from anonymous sources.
In the event that a complaint is founded on baseless allegations, the person to whom the issue is reported, together with the Chair of the Committee shall decide on appropriate action.
This policy is not meant to deal with frivolous, inconsequential or clearly immaterial matters.
Contact Information for Chair of the Committee
Contact Information for Chair of the Board
This Policy shall have effect from November 2012
Frequency: 12 months
Last revision: May 2015
Board Approval: November 2015
Investigate the complaint reported or designate an investigator Document the findings and any action taken
Submit a copy of the report related to results from the investigation, to the member of the Executive Team responsible, and the Chair of the Committee
Ken Skingle, Chair, Finance & Audit Committee