Whistleblower Policy

WHISTLEBLOWER POLICY

Purpose

The Calgary Drop-In & Rehab Centre Society (“the DI”) is committed to open, accountable, ethical, and transparent governance, which encourages a culture of integrity and honesty. An important aspect of accountability and transparency is a mechanism to enable employees to voice concerns in a confidential and effective manner when they discover information which they believe portrays serious malpractice or is unethical.

To meet current standards in possible accounting and auditing irregularities and fraud, as well as to discourage illegal activity and unethical business conduct, the DI has developed this Whistleblower Policy. This policy is intended to provide guidelines and a safe environment where employees are encouraged to speak up or raise issues that have serious concerns or implications without risk of discrimination, reprisal, or disclosure of their identities where prior consent is not given. The DI protects the confidentiality and anonymity of the person making a report, unless it is incompatible with a fair investigation required by law, or the person includes personal identifiable information which may reveal their identity during the review/investigation.

This policy acts under the general authority of the DI policies and procedures, specifically the Staff Code of Conduct. Any relevant legislation, both provincial and federal, will maintain authority over this policy.

Scope

This Policy applies to all DI employees, students, volunteers, and contractors relative to DI operations.

Definition

A whistleblower as defined by this policy is a person who reports an activity that they consider to be illegal or dishonest to one or more of the parties specified in this policy. The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities.

Examples include but are not limited to:
1. Concerns relating to financial, accounting, and auditing practices;
a) Fraud, including falsification of records;
b) Breaches of internal financial controls, “side deals”, or “under the table” dealings with outside parties for personal benefits;
c) Unethical or illegal practices;
d) Unauthorized use, misuse, or waste of DI assets or funds.

2. Concerns relating to quality or malpractice of care:
a) Abuse of individuals;
b) Negligence of vulnerable persons.

3. Violations of human resource policies and legislation
a) Bullying, harassment, or sexual misconduct;
b) Discrimination of any kind.

4. Other examples
a) Criminal offenses of any kind;
b) Danger to health and safety of clients or employees;
c) Conflict of interest.

The DI will not retaliate against a whistleblower. This includes, but is not limited to, protection from retaliation in the form of any employment action such as termination, compensation decrease, or poor work assignments and threats of physical harm. Any whistleblower who believes they are being retaliated against should contact Human Resources immediately.

Guidelines

Reporting Responsibility
It is the responsibility of every employee who is aware of or suspects a violation of the DI’s policies or has a matter of concern, to report the incident as soon as possible using the reporting standard in this policy.

Initial Reporting Steps
Employees who feel comfortable doing so should first report their concern as follows:
a) Employees shall report their concern to their direct Supervisor, their Manager, and/or Human Resources, recognizing that this depends on the seriousness and sensitivity of the issues involved and who is suspected of wrongdoing. Any issue brought to a supervisor shall be immediately forwarded to the related Director and/or Senior Director and the Executive Director.
b) In any case, employees may submit their concern directly to a Director, Senior Director, or to the Executive Director of the DI. A concern involving a Director or Senior Director should be submitted directly to the Executive Director.

Whistleblower Reporting Process
The DI has partnered with an independent firm, ClearView Strategic Partners Inc. (“ClearView”), who will gather the information required for a whistleblower complaint to provide back to management anonymously and confidentially. Persons who wish to speak up about any concerns observed at the DI can do so using any of the following four channels:

1. Online – go to www.clearviewconnects.com and follow the step-by-step instructions;
2. Telephone hotline live operator – Call 1 800 967 5224. The operator will help you submit your report;
3. Telephone hotline voice message – Call 1 800 967 5224. You will be able to leave a voicemail message containing your report;
4. Mail – Send a confidential hard copy report to the following address: ClearView Connects™, P.O. Box 11017, Toronto, Ontario, Canada, M1E 1N0;
When you have submitted a report using either the web-based system or telephone hotline live operator reporting option, you will be given a login ID and password so that you can login again later to check the status of your report. Be sure to keep your login ID and password in a safe place so that you can access the report again. ClearView and the DI do not know your login ID and password and will be unable to retrieve them for you if you forget or lose them.
Note that login IDs and passwords cannot be provided to you when submitting your report using the telephone hotline voicemail, or hard copy mail reporting options. So, if you would prefer the opportunity to follow-up on the status of your report (which we encourage you to do), please submit your report using the online or telephone hotline live operator reporting options.
Here is how ClearView protects your anonymity:
· If you use ClearView Connects™ online: the session is encrypted, and your IP address is not identified with your report.
· If you call the telephone hotline and speak to a live operator: the call is not recorded, nor is caller ID used. The report is transcribed by a trained operator into the ClearView system verbatim (in your exact words, word for word).
· If you call the telephone hotline and leave a voicemail: the recording is transcribed by trained ClearView personnel into the system verbatim and then erased. As well, caller ID is not used.
· If you send a report by mail: handwritten letters will be transcribed and typewritten reports will be scanned and uploaded into the ClearView system, and the original hardcopy will be destroyed. Only authorised ClearView personnel can access the Post Office mailbox.
· In all cases, the report data stays on ClearView’s secure servers.

Acting in Good Faith

Any person submitting an allegation must be acting in good faith with reasonable grounds for believing there is a breach of the Code of Conduct or inappropriate practices. An employee who makes an unsubstantiated allegation which is knowingly false or has been made maliciously or in bad faith will be subject to disciplinary action, which may include termination of employment.

No Retaliation

No person who, in good faith and under this policy, reports any violation or submits a concern shall suffer harassment, retaliation, or adverse consequences. Any individual who retaliates against someone reporting an incident in good faith will be subject to discipline, which may include termination of employment.

If an employee feels that they are being harassed or are facing retaliation due to a complaint made, they are advised to contact Human Resources, their Supervisor, or Director as applicable, to file a report on this.

Confidentiality

The DI will treat every allegation made as confidential and privileged although there may be cases where the incident reported could identify the individual reporting the complaint. Therefore, the identity of any person who makes a good faith allegation will, to the best of our ability, be kept confidential and anonymous if requested, unless it is incompatible with a fair investigation or required by law. In such instances the person registering the concern will be informed in advance. Information will only be made available on a need-to-know basis.
The DI will pay due regard to fairness to any individual named in the allegation, the seriousness of the issue, and credibility of the information.

Complaints & Reports

All complaints or reports will be taken seriously. The DI is committed to investigating allegations of improper activity and inappropriate behaviours as soon as possible, considering the seriousness and complexity of the reported issue. Employee Services, or an outside investigation firm, will conduct an objective, timely, and fair investigation, respecting the rights of individuals. Complacency, deception, or cover-up of wrongdoings and violation against the Code of Conduct are not tolerated.

Investigation

Investigations will be done through a trauma-informed approach, based on our operating work environment. If on preliminary investigation the allegation is judged to be without substance or merit, the matter will be dismissed and the employee disclosing the concern will be informed of the decision and reasons for such a dismissal.

During the investigation, employees being investigated may be placed on an administrative leave with pay depending on the severity of the allegation and if it is determined that their presence at work may interfere with the investigation. Employees involved or interviewed during the investigation must maintain confidentiality and refrain from revealing anything about the investigation. This is to ensure that the integrity of the investigation is not compromised. Where it is confirmed that this is not adhered to, the employee may face disciplinary action, up to and including termination of employment.

If at the conclusion of an investigation the DI determines that a violation or wrongdoing has occurred, the DI will take remedial action equal to the severity of the offence.

If the complaint was brought to the DI through ClearView, the ClearView complaint file will be updated with the results of the investigation. If the complaint was brought to the DI through either DI staff or Human Resources, the employee will be updated on the investigation results by Human Resources.

Retention of Reports

The DI will maintain a record of all reported allegations. All documents related to reporting, investigation, and enforcement of this policy will be kept in accordance with DI policies and applicable law.

A summary report will be provided to the Board of Directors on a bi-annual basis.