The International Society for the Prevention of Child Abuse and Neglect (ISPCAN) strives to serve its members and partners through acceptable, ethical and legal practices. ISPCAN requires its Councilors, employees and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. The purpose of this Whistleblower Policy is to establish a procedure for employees and members to raise good faith concerns regarding suspected violations of law on the part of ISPCAN or to identify potential violations of ISPCAN policy and to protect employees who take such actions from retaliation. This policy does not excuse knowingly providing false information.
ISPCAN is committed to maintaining a workplace where employees are free to raise good faith concerns regarding ISPCAN’s business practices, specifically:
- Reporting suspected violations of law on the part of ISPCAN, including but not limited to federal laws and regulations;
- Providing truthful information in connection with an inquiry or investigation by a court, agency, law enforcement, or other governmental body; and
- Identifying potential violations of ISPCAN policy.
This policy is meant to be construed as an open door policy and it is suggested that employees share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor is in the best position to address an area of concern. However, if the employee is not comfortable speaking to his or her supervisor or is not satisfied with the supervisor’s response to a reported violation, the employee is encouraged to speak to the Director of Finance and Operations or the Executive Director. In the event that the employee is not satisfied with the response of staff management, the employee may bring his or her concern to ISPCAN’s Legal Advisor, Personnel Committee Chair or Treasurer.
Contact information for these individuals follows:
Legal Advisor: Henry J. Plum
Personnel Committee Chair: Joan van Niekerk
Treasurer: Dr. Martin A. Finkel
For all cases of suspected fraud or when an employee is not satisfied or is uncomfortable with following ISPCAN’s open door policy, the employee should feel free to directly contact ISPCAN’s Legal Advisor, Treasurer or Personnel Committee Chair. An employee who wishes to report a suspected violation of law or ISPCAN policy (that is, to act as a “whistleblower”) may do so confidentially and anonymously if preferred.
All reports of suspected violations should include as much information as possible to permit a thorough and complete investigation and evaluation of the complaint. This includes, but is not limited to, material evidence, names of people able to corroborate the complaint, and specific dates and places of occurrence.
ISPCAN will use its best efforts to protect whistleblowers against retaliation and expressly prohibits any form of retaliation, including harassment, intimidation, adverse employment actions, or any other form of retaliation, against employees who raise suspected violations of law, cooperate in inquiries or investigations, or identify potential violations of ISPCAN policies. Any employee who engages in retaliation will be subject to discipline, up to and including termination.
Any employee who believes that he or she has been subjected to any form of retaliation as a result of reporting a suspected violation of law or policy should immediately report the suspected retaliation to one of the following: the Legal Advisor, Treasurer, Personnel Committee Chair, that employee’s supervisor, the Director of Finance and Operations, or the Executive Director. ISPCAN supervisors, managers, directors, or Councilors who receive complaints of retaliation must immediately inform the Personnel Committee Chair, who will inform the Legal Advisor and the other members of the Personnel Committee.
Protection from retaliation is not intended to prohibit directors, managers or supervisors from taking action, including disciplinary action, in the usual scope of their duties based on valid performance related factors, nor is it intended to preclude disciplinary action against individuals who report baseless allegations. Any person filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing that the information disclosed indicates a violation. Any allegations that prove to be false or unsubstantiated and that prove to have been made maliciously or knowingly will be viewed as a serious offense requiring disciplinary action, including immediate dismissal.
Reports of suspected violations of law or policy and reports of retaliation will be investigated promptly and in a manner intended to protect confidentiality, consistent with a full and fair investigation. The Personnel Committee Chair, after consultation with the Legal Advisor and President, will lead the investigations. The investigating parties will notify the concerned individuals of their findings directly and will prepare other reports as indicated by the circumstances. A summary of all such reports will be presented to the Officers during their semi-annual meetings.