General
The Cystic Fibrosis Foundation Staff Conduct and Conflict of Interest Policy and Code of Ethics require employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of the organization must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations.
The objectives of the Cystic Fibrosis Foundation Conscientious Employee Policy are to establish policies and procedures for:
- The submission of concerns regarding any potential illegal acts, fraud, or abuse by employees or others associated with the organization, on a confidential and anonymous basis.
- The receipt, retention, and treatment of complaints received by the organization regarding accounting, internal control, or financial matters.
- The protection of employees reporting concerns from retaliatory actions.
Reporting Responsibility
Each employee of the CF Foundation has an obligation to report in accordance with this Policy (a) questionable or improper financial or accounting matters, (b) violations or suspected violations of the CF Foundation’s Staff Conduct and Conflict of Interest Policy, and (c) violations or suspected violations with regard to illegal acts, fraud or abuse (hereinafter collectively referred to as Concerns).
Employees cannot exempt themselves from the consequences of their own misconduct by reporting the issue, although self-reporting may be taken into account when determining appropriate disciplinary action.
Acting in Good Faith
Anyone reporting a Concern must act in good faith and have reasonable grounds for believing the information disclosed indicates an improper financial or accounting practice, violation of the Staff Conduct and Conflict of Interest Policy, violation of the Code of Ethics, or fraud. The act of making allegations that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in discipline, up to and including termination.
Authority of Audit Committee
All reported Concerns will be forwarded to the CF Foundation Board of Trustees Audit Committee Chairman in accordance with the procedures set forth herein. Management will be responsible for investigating all Concerns unless the Audit Committee Chairman deems that the Audit Committee should perform the investigation.
No Retaliation
This whistleblower policy is intended to encourage and enable employees to raise Concerns within the Foundation for investigation and appropriate action. With this goal in mind, an employee who, in good faith, reports a Concern will be protected from any form of retaliation or retribution. Any form of retaliation against an employee who reports a Concern in good faith is strictly prohibited, and any employee who commits or condones any form of retaliation will be subject to discipline up to, and including, termination.
Reporting Concerns
Employees are strongly encouraged to report problems and concerns, via their direct supervisor, or the Vice President of Human Resources. If an employee prefers, an independent hotline has been established to report Concerns anonymously or in confidence. If employees disclose their identities, they will be held in confidence to the fullest extent allowed by law.
Handling of Reported Violations
Management shall promptly address all reported Concerns. Depending upon the allegations, management may conduct an investigation to determine the appropriate corrective action, if needed. The Audit Committee Chairman will be informed of the status of Concerns and the resolution of Concerns will be discussed with the Audit Committee.
If deemed necessary by the Audit Committee Chairman, the Audit Committee has the authority to retain outside legal counsel, accountants, private investigators, or any other resource deemed necessary to conduct a full and complete investigation of the allegations.
Confidentiality
Reports of Concerns, and investigation pertaining thereto, shall be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. Disclosure of reports of Concerns to individuals not involved in the investigation will be viewed as a serious disciplinary offense and may result in discipline, up to and including termination of employment.
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