NCRA Whistleblower Policy
The Association is committed to compliance with the laws and regulations to which it is subject and to promulgating policies and procedures to interpret and apply these laws and regulations. This policy governs reporting and investigation of allegations of suspected improper activities that violate laws to which the Association is subject. Employees who in good faith report the commission or suspected commission of criminal activity to a regulatory or law enforcement agency or to designated members of the Association management team, or who provide truthful information or otherwise assist in an investigation regarding such conditions or events, are protected from retaliation. Retaliation includes adverse actions with respect to employment such as demotions, wage or hour reductions, denial of raise or benefits if otherwise eligible, and termination of employment.
Questionable conduct to be reported
If an employee suspects that another employee or any other person affiliated with the Association has engaged in questionable conduct involving financial improprieties, misuse of the Association’s assets, conflicts of interest, or other fraudulent, dishonest, or illegal conduct detrimental to the interests of the Association, its members or staff, that employee is strongly encouraged to report it. This misconduct may include outright theft (of equipment or cash), fraudulent expense reports, misstatements of any accounts to any manager or to the Association’s auditors, or even a conflict of interest that may result in financial harm or public discredit to the Association.
If an employee suspects that an employee or other person affiliated with the Association has engaged in conduct described above, an employee may report it either confidentially or anonymously—and in either case the employee will be protected from retaliation for making such a report in good faith. An employee can make a confidential report to any of the following at any time: (1) Director, Human Resources and Administration (2) Senior Directors or (3) Executive Director and CEO. The Association will promptly conduct an investigation into the matter reported, keeping the identity of the reporting employee confidential at all times to the extent permitted by the legitimate needs of the investigation and by law, unless the employee decides otherwise. Should the employee self-disclose his or her identity, the Association will no longer be obligated to maintain such confidence. The employee will be informed of the results of the investigation. If the employee wishes to submit an anonymous report, the employee may do so by U.S. mail addressed to any of the individuals designated above. The envelope should have the statement “personal and confidential” clearly written on the front. If an employee makes a report anonymously, it will not be possible to provide that individual with the results of any investigation or to follow up with the employee for additional information that may be necessary to proceed. However, the report will be carefully reviewed, and if at all possible, investigated nonetheless.
Subject to the confidentiality qualifications noted above, credible reports of improprieties in accounting, auditing, or other internal control systems and credible reports involving a material financial liability for the organization will be reported to the Finance Committee, together with the results of any investigation by management.
Reporting retaliation in violation of this policy
If, having made a report of suspicious conduct, an employee subsequently believes that he or she has been subjected to retaliation by any Association employee or other persons affiliated with the Association, the employee should immediately report it to the Director, Human Resources and Administration. If the employee believes that the subject of the report involves the Human Resources Department, the employee should report the alleged retaliation to the Executive Director and CEO or any other Senior Director. Reports of retaliation will be investigated promptly in a manner intended to protect confidentiality, consistent with a full and fair investigation. The party conducting the investigation will notify the employee of the results of the investigation.
The Association strongly disapproves of and will not tolerate any form of retaliation against employees who report concerns in good faith regarding the Association’s operations. Any employee who engages in such retaliation will be subject to discipline up to and including termination. Employees who raise in bad faith unfounded or malicious allegations of suspicious conduct are also subject to discipline, up to and including termination.