EFAA WHISTLEBLOWER POLICY

Approved by EFAA Board of Directors
September 15, 2016

EFAA requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of EFAA must practice honesty and integrity in fulfilling responsibilities and comply with all applicable laws and regulations.

Application. This Whistleblower Protection Policy applies to all of EFAA’s staff, whether full-time, part-time, or temporary employees, to all volunteers, and to all officers and directors, each of whom shall be entitled to protection.

Reporting Credible Information. EFAA has an open door policy and suggests that employees or volunteers share their questions, concerns, suggestions or complaints with their supervisor. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the Executive Director (the “Compliance Officer”) who has the responsibility to investigate all reported complaints. If there is not a level of comfort in speaking with a supervisor, or there is not satisfaction with a supervisor’s response, the individual is encouraged to speak with the Compliance Officer, unless the report relates to the Compliance Officer, in which case the report shall be made to the President of the Board of Directors. A protected person shall be encouraged to report information relating to illegal practices or violations of policies of EFAA (a “Violation”) that such person in good faith has reasonable cause to believe is credible.

Anyone reporting a Violation must act in good faith, and have reasonable grounds for believing that the information shared in the report indicates that a Violation has occurred. Staff and volunteers shall make efforts to provide information directly to the Compliance Officer or Board President before disclosing information to outside sources.

Investigating Information. The Compliance Officer shall promptly investigate each such report and prepare a written report to the Board of Directors. In connection with such investigation all persons entitled to protection shall provide the Compliance Officer with credible information. All actions of the Compliance Officer in receiving and investigating the report and additional information shall endeavor to protect the confidentiality of all persons entitled to protection.

Confidentiality. EFAA encourages anyone reporting a Violation to identify himself or herself when making a report in order to facilitate the investigation of the Violation. However, reports may be submitted anonymously by writing and mailing a report to either or both the Compliance Officer and/or the President of the Board of Directors. Reports of Violations or suspected Violations will be kept confidential to the extent possible, with the understanding that confidentiality may not be maintained where identification is required by law or in order to enable EFAA or law enforcement to conduct an adequate investigation.

Protection from Retaliation. No person entitled to protection shall be subjected to retaliation, intimidation, harassment, or other adverse action for reporting information in accordance with this Policy. Any person entitled to protection who believes that he or she is the subject of any form of retaliation for such participation should immediately report the same as a violation of and in accordance with this Policy.

Any individual within EFAA who retaliates against another individual who has reported a Violation in good faith or who, in good faith, has cooperated in the investigation of a Violation is subject to discipline, including termination of employment or volunteer status.

The procedures for implementation of this Policy shall include a process for communicating with a complainant about the status of the complaint, to the extent that the complainant’s identity is disclosed, and to the extent consistent with any privacy or confidentiality limitations. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.