The mission and values of Rise Asset Development (“Rise”) require directors, officers, employees, representatives, and volunteers to observe high standards of business, ministry and personal ethics in the conduct of their duties and responsibilities.
Employees and representatives of Rise must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations. While Rise’s internal control systems are intended to detect improper activities, even the best systems and internal controls cannot provide absolute safeguards.
The purpose of this Whistleblower Policy is to facilitate concerns about the organization regarding accounting, internal controls, auditing matters or other activities that are inconsistent or in violation of Rise’s legal, financial, regulatory and ethical responsibilities.
Rise has an obligation to expediently and thoroughly investigate and take corrective action against any serious violation of its policies and responsibilities.
This policy applies to all directors, officers, employees and volunteers of Rise.
This policy applies to improper conduct or wrongdoing, which includes, but is not limited to, activities that:
- Are unlawful or not in compliance with any laws or regulations to which Rise is subject
- Do not adhere to Rise’s accounting and internal control procedures and policies
- Do not adhere Rise operating policies and procedures
- May amount to fraud or corruption
- Reflect a real or perceived conflict of interest
- Represent the unauthorized use or misuse of Rise funds or property
- Constitute unethical or improper conduct or abuse.
Maintaining confidentiality is important to Rise. Rise will keep complaints confidential where possible – consistent with the need to conduct an adequate investigation – informing only those who absolutely must be informed.
Rise or its employees and agents may be required, and shall be permitted, to reveal identities and/or the contents of the report on a limited basis for the sole purpose of permitting a thorough and effective investigation, and as may be required by law or in court proceedings.
Rise shall notify the complainant if any circumstances arise where confidentiality may not be maintained. If applicable, the rules and regulations pursuant to the Personal Information Protection and Electronic Documents Act (“PIPEDA”), as well as any other applicable federal privacy legislation, will take precedence over the complainant’s request for confidentiality.
Anyone with concerns or complaints regarding improper conduct as in section 8.3 is expected to share their concerns by submitting a written statement with supporting evidence attached. Complaints may be sent as follows:
- Via email to email@example.com, which is monitored by the Chief Operating Officer
- Via email to any member of the Executive Team, including the Chief Operating Officer or the Chief Executive Officer
- In the event that the complaint pertains to the CEO, the complaint should be made in writing to the Rise Treasurer, as Chair of the Finance, Audit and Risk Committee (FAR) of the Board of Directors at firstname.lastname@example.org
Rise will respond to complaints as follows:
- Rise will provide the complainant with an acknowledgement of receipt within 5 business days of receiving the complaint.
- Rise will investigate the complaint and take any action necessary to address the subject matter of the complaint. This action could include the appointment of a designated investigator who could be internal or external to the organization.
- Rise will communicate in writing to the complainant addressing the complaint and any action taken within 30 days of receiving the complaint. We anticipate that many concerns may be sufficiently addressed through common problem-solving processes.
- The complainant must notify Rise in writing within 15 days as to whether they are satisfied or dissatisfied with the reply. If the complainant does not respond, a follow up written communication will be sent within 10 days of sending the findings, and if still no response is received, the complaint will be considered resolved.
If the complainant feels that their concern is not adequately addressed or if the complainant did not get a reply within the 30-day period, the complainant should follow the following procedure:
- The complainant should contact the Rise Treasurer in writing, resubmitting the complaint and attaching all information available.
- The complainant should also state the reasons why they are not satisfied with the earlier reply. The Treasurer will conduct a merit assessment of all complaints received and assess the need to proceed with a formal investigation.
- The Treasurer will report back to the person who filed the complaint within 30 days of receipt as to whether a formal investigation will be undertaken. The assessment will be made on the basis of evidence that supports the complaint.
- If a formal investigation is undertaken, the Treasurer has the responsibility to undertake any action necessary to ensure a complete and fair investigation.
HANDLING OF REPORTS
Any manager who receives a written report of an alleged violation under this policy must in a timely fashion take steps to forward the report to the CEO, in the first instance unless unavailable or inappropriate, or the Treasurer.
The CEO, upon receipt of any such report, shall inform the Treasurer and the Chair of the Board immediately, and the Treasurer, upon receipt of a report, shall inform the Chair of the Board.
The CEO will be informed of any allegation unless the Chair of the Board and Treasurer have reason to believe that management should not be aware of or involved in the investigation.
The Treasurer, upon receipt of any report, shall be responsible to ensure appropriate and expeditious action is taken to investigate the allegation, after first determining who will lead such investigation. While the Treasurer may determine that management is best positioned to conduct the investigation directly, the FAR Committee shall continue to maintain oversight of any investigation and approve all follow up actions or other responses undertaken by management until the matter is closed.
Subject to maintaining appropriate confidentiality, as described above, the Treasurer and the Chair of the Board will report, in such detail as they determine to be appropriate, all matters to the Board as soon as reasonably practical. The Board shall also be informed with respect to all actions taken to follow up on any matter until it is officially closed.
The Treasurer shall ensure that there is appropriate follow up communication with the original complainant, as outlined in Section 8.4 once a matter is closed under this policy.
ACTING IN GOOD FAITH
Anyone filing a complaint alleging misconduct must act in good faith and have reasonable grounds for believing the information disclosed indicates wrongdoing. Making allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false could result in disciplinary action up to and including termination.
No Board member or staff member who makes a report in good faith shall suffer retaliation. Retaliation means any direct or indirect detrimental action threatened or taken against an individual. Employees should feel confident when reporting violations as described above or when assisting in investigations of such alleged violations.
Rise will not allow or tolerate retaliation or discrimination of any kind by or on behalf of Rise and its employees, officers and/or Directors against any employee making a good faith complaint of, or assisting in the investigation of, any matter under this policy.
FILE MANAGEMENT AND RECORD KEEPING
A record of all complaints received will be retained on file. Files will include the original complaints as well as all other relevant notes and documents, such as signed and dated testimonies. The files will be kept separate from existing personnel files.