Crohn’s and Colitis Canada is committed to maintaining the highest standards of integrity and ethical behavior in the conduct of its business. It is the policy of Crohn's and Colitis Canada to comply with (and to require its Directors, officers, and employees to comply with) Crohn’s and Colitis Canada's Guidelines for Business Conduct (the "Guidelines") and all applicable legal and regulatory requirements in the jurisdictions in which it operates, including those related to operations, reporting and disclosure, and/or accounting and auditing controls and procedures. Each Director, officer and employee is expected to report any known or suspected violation of the Guidelines or any other applicable laws or regulations, whether accidental or deliberate. This policy is also applicable if issues of the nature described above are raised in reports received from volunteers and the general public under the Complaint Policy.
REPORTING ALLEGED VIOLATIONS OR CONCERNS
If an employee reasonably believes that any Crohn's and Colitis Canada employee or other person acting on behalf of the Crohn's and Colitis Canada has violated the Guidelines, or any legal or regulatory requirements, or any internal policy relating to operations, accounting standards and disclosures, internal accounting controls, or matters related to the external audit of Crohn's and Colitis Canada’s financial statements, that employee should immediately report his or her concern to his or her supervisor. If an employee is not comfortable reporting a concern directly to his or her supervisor, then one of the following alternatives should be followed:
- Report the concern to any other member of the senior management team;
- Report the concern directly to the CEO of the organization;
- Report the concern directly to the Chair of the Finance, Audit and Risk Committee of the Board of Directors (FARC).
Employees are encouraged to follow channels through management first, unless they have reason to believe that management may be involved or that the reporting of the matter may adversely affect them, or are otherwise uncomfortable due to some aspect of the report. Any volunteer or member of the public who has any concern related to the operations of Crohn's and Colitis Canada may follow the procedures available under the Complaint Policy. Employees receiving a complaint from such an external source are required to use this policy to advance complaints which raise issues of the nature described above. Reports under this policy must be in writing. Reports of alleged violations should be factual, rather than speculative, and should contain as much specific detail as possible to allow for proper assessment. The complaint should be candid and should clearly set forth all of the information that the person knows regarding the allegation or concern. Crohn's and Colitis Canada may, in its reasonable discretion, determine not to commence an investigation if a complaint contains only unspecified or broad allegations of wrongdoing without appropriate factual support. A report intended for the Chair of the FARC Committee or CEO shall be delivered or mailed to the current Toronto address of Crohn's and Colitis Canada and shall be clearly marked "Personal and Confidential" and "Attention: Chair of the Audit, Finance and Risk Committee of the Board of Directors" or "Attention: Chief Executive Officer".
HANDLING OF REPORTS, AND INVESTIGATION
Any manager or supervisory employee 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 Chair of the FARC. The CEO, upon receipt of any such report, shall inform the Chair of FARC and the Chair of the Board immediately, and the Chair of the FARC, 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 Chair of the FARC have reason to believe that management should not be aware of or involved in the investigation. The Chair of the FARC, 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 Chair of the FARC may determine that management is best positioned to conduct the investigation directly, the FARC 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 below, the Chair of the FARC 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.
Crohn's and Colitis Canada will make good faith efforts to keep all reports of alleged violations confidential, including the identity of the person making the report and those who are alleged to be involved in any violation. However, Crohn's and Colitis Canada 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 to permit a thorough and effective investigation, and as may be required by law or in court proceedings.
The Chair of the FARC shall ensure that there is appropriate follow up communication with the original complainant once a matter is closed under this policy.
This policy assumes that employees will act in good faith and will not make false accusations when reporting any wrongdoing or alleged wrongdoing. An employee who knowingly or recklessly makes statements or disclosures that are not in good faith could be subject to discipline, which may include termination.
Employees should feel confident when reporting violations as described above or when assisting in investigations of such alleged violations. Crohn's and Colitis Canada will not allow or tolerate retaliation or discrimination of any kind by or on behalf of Crohn's and Colitis Canada 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.