A. Purpose of the Policy
IFEX is committed to the highest standards of professional and ethical conduct in all its activities. Our reputation for honesty and integrity among our stakeholders and employees is key to the success of our organisation. This Confidential Reporting policy provides guidance so that anyone working for IFEX can raise concerns regarding questionable business practices without fear of discrimination, retaliation or harassment.
B. Scope and Application
This Policy applies to everyone who works at IFEX (that is to all Council members, employees, volunteers and consultants working for IFEX, including contract staff).
C. What to Report
Individuals are expected to promptly report, either orally or in writing, all evidence of activity that may constitute any of the following:
- suspected violations of the law, whether civil or criminal;
- suspected violations of organisational policies;
- questionable accounting, internal accounting controls or auditing practices or irregularities;
- risk to IFEX’s resources or reputation;
- breaches of occupational health and safety legislation;
- any other serious concerns regarding IFEX’s business practices.
Individuals should provide as much specific information as possible including names, dates, places and events that took place, your perception of why the incident(s) may be a violation, and what action you recommend be taken. If individuals are unsure about the best course of action to take in a particular situation, individuals are encouraged to seek guidance in the same manner as described in Section 4. Who to Contact.
D. Who to Contact
Individuals are encouraged to report concerns to their immediate supervisor or manager.
Where a satisfactory response is not received, or if the individual is uncomfortable addressing their concerns to their supervisor or manager, the individual is invited to contact any member of the IFEX Personnel Committee.
E. Confidentiality and Anonymity
IFEX will respect the confidentiality of any complaint received, except as necessary to conduct an investigation and resolve the problem in accordance with applicable legislation and IFEX’s policies. However, IFEX encourages individuals to only make anonymous reports as a last resort because of the inherent difficulty of following up on anonymously reported violations. If individuals choose to remain anonymous and do not provide sufficient detail we may not be able to commence a comprehensive investigation of their claim.
F. Investigation of Complaints
IFEX assumes that all reports made under this Policy are made in good faith, are real, legitimate and significant enough to warrant an investigation.
All complaints under this Policy will be promptly and thoroughly investigated in accordance with IFEX’s policies and procedures (normally within 60 days after a formal written complaint is received). In the event a member of the IFEX Personnel Committee is under investigation he/she will be temporarily removed from the committee. All information disclosed during the course of that investigation will remain confidential except as necessary to conduct the investigation and take any remedial action or where disclosure is required by applicable law. Depending upon the nature of the complaint, the investigation may be conducted utilizing internal management and staff or IFEX may choose to obtain external assistance. At the conclusion of the investigation, if it is determined that the complaint has been substantiated, appropriate corrective measures will be taken to address the issue with the offending party commensurate with the severity of the offence. Steps will also be taken to prevent further violations. The matter may also be reported to the appropriate outside agency to ensure compliance with all laws and regulations.
All reports in respect of matters specifically covered by this Policy, whether made to supervisors, managers or any member of the Personnel Committee will be reported to the Executive Director. In the event the complaint involves the Executive Director then the IFEX Council will be notified. The status and resolution of the investigation will be communicated to the individual if the individual has provided contact information sufficient to allow us to communicate with the individual.
G. Duty to Cooperate
Individuals have a duty to cooperate in an investigation. If individuals fail to cooperate or if individuals provide false information in an investigation, IFEX will take remedial action commensurate with the severity of the offence.
H. Prevention of Retaliation
If staff make a report under this Policy, staff will be protected from retaliation, harassment, discharge, demotion, suspension or other types of discrimination, or threats thereof, including compensation or terms and conditions of employment, that are directly related to the disclosure of such reports if staff:
- disclose the information in good faith;
- believe it to be substantially true;
- do not act maliciously or make false allegations; and
- do not seek any personal or financial gain.
Individuals will also be protected in connection with any lawful act that they (i) take to provide information, or cause information to be provided, or otherwise assist, in any investigation regarding any conduct that the individual reasonably believe constitutes a violation of law or regulation, when the investigation is conducted by a federal or provincial regulatory or law enforcement agency, or a person with supervisory authority over the individual (or another person working for IFEX who has the authority to investigate, discover, or terminate misconduct), or (ii) take to file, cause to be filed, testify, participate in, or otherwise assist in a proceeding filed or about to be filed (with knowledge of the Organisation) relating to an alleged violation of law or regulation.
If staff believe they have been unfairly or unlawfully retaliated against in respect of a report made under this Policy, staff may file a complaint with their supervisor or manager or, if staff are uncomfortable filing a report with their supervisor, with any member of the Personnel Committee.
I. False and Malicious Allegations
IFEX is proud of its reputation as an organisation with the highest standards of honesty. IFEX will therefore ensure that substantial and adequate resources are put into investigating any complaint it receives. However, it is important to realise that IFEX regards the making of deliberately false or malicious allegations as a serious offence. Such actions may result in disciplinary measures up to and including dismissal for cause and, if warranted, legal action.