3.2.4 Whistleblower Policy

The Resource Center (TRC) requires all employees, directors, officers and volunteers to promptly report any known or suspected violations of the Corporate Compliance Plan, Code of Conduct, policies and procedures, or any of the laws, rules or regulations by which TRC is governed. This policy governs the procedure used to report compliance concerns and seeks to ensure that TRC provides an environment that encourages individuals to report any suspected violations without fear of retaliation or retribution.

Form
Compliance Intake form

Scope
This policy applies to all employees, directors, officers, and volunteers of TRC. This policy is posted to TRC’s website and TRC’s Agency Policy Manual. The Board oversees implementation of the compliance with this policy.

Procedure

Duty to Report
Employees, directors, officers, and volunteers are required to report any known or suspected violations of the Corporate Compliance Plan, Code of Conduct, policies and procedures or any of the laws, rules or regulations by which TRC is governed to their supervisor, manager, the Corporate Compliance Officer or through TRC’s compliance hotline.

Process for Reporting:
Compliance concerns may be reported to:

  • Compliance Hotline: (716) 661-1011 – Callers to the Compliance Hotline may make reports anonymously. No caller is required to disclose their identity and no attempt is made to trace the source of the call or identity of the caller when the caller requests anonymity.
  • Compliance E-mail: TRC.Compliance@resourcecenter.org

NOTE: TRC treats all reports made under this policy confidentially and will protect the identity of the individual who has made a report to the maximum extent possible.

Tracking/Investigations of Reports

Any manager or supervisor who receives a report of a suspected violation will:

  • Complete a Compliance Intake Form
  • Immediately direct the Compliance Intake Form to the Compliance Officer

The Compliance Officer will:

  • Complete a Compliance Intake Form for all reports received through the Compliance Office
  • Upon receipt of a Compliance Intake Form, the Compliance Officer or their designee conducts an investigation.
  • Prepare a report to the Audit Committee at least annually summarizing incidents reported, investigatory findings and any corrective actions taken

NOTE: The person who is subject of the whistleblower complaint may not be present or participate in board or committee deliberations or vote on the matter relating to the complaint (except that nothing prohibits the person from providing background information or answering questions before deliberations/voting begin)

Non-Retaliation/Non-Retribution

All employees, directors, officers and volunteers of TRC are strictly prohibited from engaging in any act, conduct or behavior which results in, or is intended to result in, retaliation or retribution against any individual for reporting their concerns, in “good faith”, relating to a possible violation of TRC’s Corporate Compliance Plan, Code of Conduct, policies and procedures or any of the laws, rules or regulations by which TRC is governed.

If a TRC employee, director, officer or volunteer believes that they have been retaliated against for initiating a report or complaint or for participating in any investigations related to such report or complaint then the retaliation should be reported to their supervisor, manager, the Corporate Compliance Officer or TRC’s Compliance Hotline as soon as possible.