Partners in Personal Assistance

Policy and Procedures

Policy # A.004                                    Whistleblower Policy

1.            Policy

If any employee, Consumer, volunteer, or Board member, or anyone involved with PPA becomes aware that, or suspects that, PPA is engaging in an illegal activity, or engaging in activities that violate PPA’s policies and procedures or code of ethics and conduct, and reports the activity to PPA’s staff, Board, or local, state, or federal officials, PPA will not punish the employee or volunteer in any way for the report.

PPA, its Board and its staff are required to follow the law and report to the appropriate governmental authorities any illegal activity they know about or witness.

2.            Definitions

Punishments that are not allowed include firing, demotion, suspension, harassment, failure to consider an employee for promotion, or any other kind of discrimination.

3.            Application

Employees, Consumers, volunteers, and Board members of PPA.

4.            Standards

-              PPA maintains an open door policy. If you have any questions or concerns, and you want to talk with someone about your concerns, you may speak in confidence (and anonymity, if you wish) to PPA’s Management (as designated by the Board) or the Corporate Compliance Officer. If you feel uncomfortable speaking with someone in Management, you may speak to the Board (preferably the Chair or Co-Chair). If you suspect that PPA is engaging in any illegal or financially inappropriate activities, you may likewise discuss the issue in confidentiality with Management, or with the Board, or you may submit a report to local, state, or federal governments. PPA will not punish you in any way for reporting illegal or financially inappropriate activities that PPA may be engaging in.

-              The PPA Board will begin investigation of a complaint or allegation within 48 hours of a Board member receiving notification of it.  The Board’s designated investigator will have an initial report within one month of the allegation being made.

-              Even if the claims are unfounded, PPA will not retaliate against you in any way. The law does not force you to prove your suspicions or concerns. A reasonable belief that illegal activity exists is enough to protect you from punishment or retribution. However, any allegations that prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

-              PPA takes all complaints seriously. PPA will investigate all reports of illegal or improper activities submitted by employees, volunteers, or members of the Board and, if necessary, will fix the problems. PPA will protect your confidentiality to the extent possible, consistent with the need to conduct an adequate investigation.

Re-approved by a majority vote of the Board of Directors 1/29/2014; revision passed by a majority vote of the Board of Directors 9/25/2013; previously revised and approved 9/23/2010. Created 10/24/2007.

From the PPA Corporate Compliance Statement:

“The Board of Directors appoints a Corporate Compliance Officer as the primary point of contact for all corporate compliance issues by all employees and Board members.  The Board will also create a Compliance Committee to review compliance issues and working with the Compliance Officer. This individual will fully investigate all problems brought to her/his attention.  The Board of Directors will develop a comprehensive corporate compliance checklist and continually monitor it for current relevancy and consistent utilization.   The Compliance Officer will report to the Board of Directors at least quarterly.  The Compliance Officer will therefore automatically have the authority to view and review all documents and other information that she or he deems relevant to compliance activities. 

It is the Special Project Manager’s responsibility as the Corporate Compliance Officer to oversee the implementation of PPA’s compliance program.  The SPM is, therefore, entitled to rely, in good faith, on officers and employees as well as corporate professional experts and advisors.  The Corporate Compliance Officer will complete an annual compliance checklist and present the results to the Board.

Any individuals reporting a compliance issue will be held harmless during the investigative process and will not be subject to any form of retaliation. All processes for resolution shall take no longer than 45 business days from the point of issuance to resolve. Employees may ask questions of or approach the compliance officer with any issues or concerns at any time and in any way, including in writing or aloud.  The Compliance Officer will maintain that employee’s confidentiality, but will document and date what the employee tells the compliance officer.

The Compliance Officer will keep the executive director updated on issues relating to compliance violations and will prepare for the Board of Directors, at minimum, an annual summary of allegations containing investigations and/or complaints processed a complete description of all corrective action taken, and any resulting recommendations for changes to PPA policy and/or procedures.”