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Immune Deficiency Foundation (IDF)
Reporting Malfeasance or Misconduct (Whistleblower)

Policy originally approved by the Board of Trustees on January 28, 2012
Addition approved by Board of Trustees on June 27, 2013
Revision Approval by Board of Trustees September 5, 2017

WHISTLEBLOWER POLICY & PROCEDURE

Policy
The Immune Deficiency Foundation encourages trustees and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of the organization should practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations. For volunteers, IDF has language in their general volunteer handbook and agreement.

The objective of the Immune Deficiency Foundation’s Whistleblower Policy is to establish a policy to (1) encourage and enable trustees and employees to report internally suspected questionable or improper accounting or auditing matters and/or suspected violations of applicable laws and regulations (herein collectively referred to as Concerns), so that the Immune Deficiency Foundation can address and correct inappropriate conduct and actions; (2) for the receipt and retention of reported Concerns; and (3) for the protection of trustees those individuals reporting Concerns from retaliation, harassment, or adverse employment consequences related to complaints of organizational wrongdoing.

The policy includes reporting of actions, including but not limited to:

  • Theft
  • Financial reporting that is intentionally misleading
  • Improper or undocumented financial transactions
  • Improper destruction of records
  • Improper use of assets
  • Violations of the organization’s conflict of interest policy
  • Any other improper occurrences regarding cash, financial procedures or reporting

Reporting Responsibility
Each trustee and employee of the Immune Deficiency Foundation has an obligation to report in accordance with this Whistleblower Policy within 90 days of discovering the violation.

Reporting Procedure
Employees should share their Concerns with someone who can address them properly. In most cases their supervisor is in the best position to address a Concern. However, if the employee is not comfortable speaking with the supervisor about the Concern, the employee is encouraged to speak with someone in Human Resources or anyone in management with whom they are comfortable in approaching. Supervisors and managers are required to report suspected Concerns to the Immune Deficiency Foundation’s chair of the finance & audit committee.

For suspected fraud, or when employees are not satisfied or are uncomfortable with following the open door policy, employees should contact the chair of the finance & audit committee directly by email at financeauditcommittee@primaryimmune.org.

Trustees should submit Concerns in writing directly to the chair of the finance & audit committee. Contact information for the finance & audit committee chair may be obtained from the senior financial official of the corporation.

Handling of Reported Violations
The finance & audit committee shall address all reported Concerns. The committee chair shall notify the committee and the President & CEO of any such report within three business days. The committee chair will notify the sender and acknowledge receipt of the Concern within five business days, if possible. It will not be possible to acknowledge receipt of anonymously submitted Concerns.

All reports will be investigated by the finance & audit committee, and appropriate corrective action will be recommended to the board of trustees, if warranted by the investigation. In addition, action taken must include a conclusion and/or follow-up with the complainant for complete closure of the Concern.

The finance & 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.

Authority of the Finance and Audit Committee
All reported Concerns will be forwarded to the Finance and Audit committee in accordance with the procedures set forth herein. The finance & audit committee shall have the authority to investigate all reported Concerns and to report its findings and make appropriate recommendations to the board of trustees, with respect to those Concerns.

Acting in Good Faith
Anyone reporting a Concern must act in good faith and have reasonable grounds for believing the information reported indicates a violation of the law, or constitutes an inappropriate accounting or financial practice. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offence and may result in discipline, up to and including termination of employment. Such conduct may also give rise to other actions, including civil lawsuits.

Confidentiality
Reports of Concerns, and investigations pertaining thereto, shall be kept confidential to the extent practical, 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. Such conduct may also give rise to other actions, including civil lawsuits.

No Retaliation
This Whistleblower Policy is intended to encourage and enable trustees and employees to raise Concerns within the organization for investigation and appropriate action. With this goal in mind, no trustee or employee who, in good faith, reports a Concern shall be subject to retaliation or, in the case of an employee, adverse employment consequences related to whistleblower complaints. Moreover, an employee who retaliates against someone who has reported a Concern in good faith is subject to discipline up to and including termination of employment.

Statement of Understanding
I have read and understand the Immune Deficiency Foundation’s Whistleblower Policy.

Name: ________________________________________________________________

Signed: _______________________________________________________________

Date: _________________________________________________________________