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Rockland Hospital Guild, Inc.

Whistleblower Protection Policy

The Rockland Hospital Guild, Inc. requires employees, directors, officers, Board members, and consultants to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the Rockland Hospital Guild, Inc. (RHG), we strive to practice honesty and integrity in fulfilling our responsibilities, and comply with all applicable laws and regulations. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally, so that RHG can address and correct inappropriate conduct and actions. It is the responsibility of all employees, volunteers, board members, officers, and consultants to report concerns about violations of RHG’s Code of Conduct or suspected violations of laws or regulations that govern RHG’s operations. Any individual that violates this Whistleblower Policy may be subject to disciplinary action, up to and including termination.

No Retaliation

It is against the values of RHG, and this policy, for anyone to retaliate against any employee, volunteer, Board member, or consultant who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, suspected fraud, or suspected violation of any policy or regulation governing the operations of RHG. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

Retaliation, for the purposes of this Policy, includes but is not limited to, threats of physical harm, loss of job, punitive work assignments, or impact on salary or work schedule. Whistleblowers who believe that they have been retaliated against may file a written complaint with the compliance officer. Any complaint of retaliation will be promptly investigated, and appropriate corrective measures taken if allegations of retaliation are substantiated. This protection from retaliation is not intended to prohibit supervisors from taking action, including disciplinary action, in the usual scope of their duties and based on valid performance-related factors.

Reporting Procedure

RHG has an ‘open door policy’ and encourages employees to share their questions, concerns, or complaints with their Supervisor or the compliance officer. If you are not comfortable speaking with your Supervisor you are encouraged to speak directly with the RHG Compliance Officer. Supervisors are asked to report complaints or concerns about suspected ethical and legal violations in writing to the RHG’s Compliance Officer, who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns by phone or in writing directly to the organization’s Compliance Officer  (in writing, by email or text message).

Compliance Officer

The RHG’s Compliance Officer is responsible for overseeing the Whistleblower Protection Policy, for ensuring that all complaints about unethical, fraudulent, or illegal conduct are investigated and resolved. The Compliance Officer will advise the Executive Director, the Board of Directors, and the Compliance Committee of all complaints and their resolution, and will report to the Chief Financial Officer on compliance activity relating to accounting, improper billing practices, or alleged financial improprieties.


Acting in Good Faith

Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false may be viewed as a serious disciplinary offense.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the individual filing the complaint. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

The Compliance Officer will contact the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation.