Communicating Concerns Regarding Our Business Practices
Policy Overview
Our aim is to ensure that the Riverdale YM-YWHA and its employees maintain the highest standards of ethical conduct. In line with that commitment, we ask that any employees who have serious concerns about the propriety of any of our business and/or clinical practices to come forward and voice their concerns to appropriate Riverdale Y personnel.
Employees are often the first to realize that an issue has arisen concerning the proper conduct of the Y’s operations. However, they may decide not to express their concerns because they feel that speaking up would be disloyal to their colleagues or the Y, or may fear a negative response regarding their action. This policy makes it clear, however, that employees may raise any legitimate concerns they may have about the ethical conduct of the Y’s operations, without fear of a negative response. Ensuring that these concerns are properly brought to our attention encourages a culture of openness, and provides a key tool in enabling our delivery of good business practices.
How To Raise A Concern
If you identify any issues concerning the proper conduct of the Y’s operations (by employees, managers, contractors or clients), please report these issues immediately to your supervisor or the HR Department. If for any reason this is not a viable option, you are encouraged to communicate these concerns directly to the Y Compliance Officer (Board President) or the Y’s Executive Director. All such concerns should be in writing, and should contain a brief explanation of the background of the concern and of the reasons why you believe the concern is serious.
Our Review Process
An employee’s concern will be reviewed as expeditiously as possible. Generally, the concern will be forwarded to the Y’s Compliance Officer (Board President), who is responsible for addressing concerns and overseeing investigations regarding our business practices. In most circumstances, after receiving notice of an employee concern, the Compliance Officer (Board President) will review the matter and provide an initial assessment to the employee, which will include the following:
- An acknowledgment that the concern has been received.
- A summary of the Y’s understanding of the concern.
- A notice of whether further review will take place and, if not, why not.
- If a further review will take place, a general indication of how the Y proposes to conduct such review.
- An explanation of staff support mechanisms.
Further review, if necessary, will take place as soon as practicable after the Compliance Officer’s (Board President’s) initial assessment. The length, scope and format of the review will depend on the specific circumstances surrounding the employee’s concern. Generally speaking, the Compliance Officer (Board President) may take all actions (including conducting interviews, collecting facts and reviewing pertinent documents) that he/she believes are required to assess the validity of the concern and (if necessary) the methods by which the Y can best resolve the situation that has caused the concern. After conducting this review, the Compliance Officer (Board President) will provide his/her recommendations to the Y management. The Y management, in consultation with the Compliance Officer (Board President), then will determine the manner in which the employee’s concern will be addressed.
During the investigation, the amount of contact between the Y and the employee who raises a concern will depend on the nature of the concern, the complexity of the investigation, and the clarity of the information provided. If necessary, the Y may seek further information from the employee. Subject to legal constraints, the Y shall provide an employee who raises a concern with a summary of the Compliance Officer’s (Board President’s) review and/or the Y management’s final determination.
[Should you wish the Claimant choose to appeal the conclusions and findings of the report, the Claimant shall notify the Compliance Officer (Board President) of their wishes and the Compliance Officer (Board President) will present the claims and facts gathered to the Board of Directors who will review the facts and take necessary action.]
Confidentiality
Although the Y cannot guarantee the privacy of each employee who raises a concern under this policy, we will strive, to the extent practicable, to respect each individual’s privacy. Concerns expressed anonymously will be considered at the Y’s discretion, taking into account issues such as (but not limited to) the seriousness of the issue raised, the credibility of the concern, and the likelihood of confirming the allegation(s) from other sources.
Retaliation Is Prohibited
Our policy invites all employees to act responsibly to uphold the reputation of the Y and to maintain public confidence in our work ethic and products. Accordingly, the Y expressly forbids any retaliation against an employee who raises legitimate concerns regarding the Y’s proper business practices. In addition, the Y will take all practicable steps to minimize the inconveniences an employee may experience as a result of an investigation (for instance, if an employee is asked to meet with the HR Department to discuss his/her concerns, the Y may modify the employee’s work schedule in order to make such meeting as convenient as possible).
Questions
Employees who have any questions concerning this policy should feel free to contact the HR Department.
