General
The Cystic Fibrosis Foundation Standards of Conduct and Code of Ethics require employees to observe the highest standards of professional 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 committed by employees or others associated with the organization, on a confidential and anonymous basis.
- The reporting of any suspected Code of Ethics or Standards of Conduct violations committed by employees, including members of management, or others representing the CF Foundation, 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 who report concerns from retaliatory actions.
Reporting Responsibility
Informed and alert employees play a critical role in protecting the CF Foundation from illegal acts, fraud, and abuse. The occurrence of such misconduct threatens the CF Foundation's ability to perform its operations and complete its mission. Therefore, 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 Standards of Conduct, and (c) violations or suspected violations with regard to illegal acts, fraud or abuse (hereinafter collectively referred to as Concerns).
Fraudulent or illegal acts addressed by this policy include but are not limited to the following:
- Embezzlement of Foundation money, securities or other valuable assets;
- Misappropriation of Foundation property, equipment or supplies for personal or other non-business related use;
- Using Foundation resources to purchase goods or services for personal or other non-business related use;
- Falsification of personal expense reports or time records;
- Taking bribes or kickbacks or conducting other fraudulent activity with Foundation vendors;
- Entering into contractual relationships that are either illegal or prohibited by Foundation policy;
- Intentional falsification of the Foundation's financial records including invoices and transactions;
- Removing or destroying Foundation records or equipment without authorization;
- Misuse of confidential Foundation information; and
- Other criminal behavior.
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 Standards of Conduct, 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. Retaliation includes, but is not limited to, the discharge, suspension, or demotion of an employee or other adverse employment action taken against an employee in the terms and conditions of employment. 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. Employees who believe they have been retaliated against should contact the Vice President of Human Resources.
Reporting Concerns
Employees are strongly encouraged to report problems and concerns, via their direct supervisor, the Internal Audit Group, or the Vice President of Human Resources. If an employee prefers, an independent hotline is available to report Concerns anonymously or in confidence. The independent hotline accepts calls 24 hours a day, 7 days a week.
Handling of Reported Violations
Management shall promptly address all reported Concerns. Depending upon the nature of 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 all 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 related investigations are kept confidential to the extent possible, consistent with the need to enable an investigation and as required by law. In certain cases, the Foundation may be legally compelled to disclose the identity of an individual reporting a Concern. If possible, the Foundation will attempt to give the individual reporting the Concern notice and obtain consent prior to releasing information about the individual reporting the Concern. When possible, the Foundation will inform the individual reporting the Concern of the status of the investigation. The disclosure of reports of Concerns to individuals not involved in the investigation is viewed as a serious offense and may warrant severe disciplinary action.