The Protected Disclosure Policy (“the Policy”) encourages employees, Board members, volunteers, and other stakeholders to raise any serious concerns about the activities or conduct of Big Brothers Big Sisters of Eastern Newfoundland (BBBSEN) in an open, transparent, and secure manner.
Scope
This Policy applies to all employees, Board members, volunteers, consultants, and external stakeholders who are engaged with BBBSEN.
Policy Statement
BBBSEN is committed to maintaining the highest ethical standards, conducting its business with integrity, and complying fully with all applicable laws, regulations, and organizational policies. This Policy provides a confidential and secure process for employees, Board members, volunteers, and stakeholders to report any concerns about misconduct or wrongdoing. It ensures that those reporting in good faith are protected from reprisal or victimization.
This Policy covers situations where any BBBSEN employee, Board member, or stakeholder has evidence of actions that could include:
- Accounting, auditing, or financial fraud or misrepresentation;
- Violations of federal or provincial laws, resulting in fines, damages, or harm to BBBSEN’s reputation;
- Unethical business conduct, in violation of BBBSEN’s Codes of Ethics or policies;
- Threats to health, safety, or well-being of BBBSEN employees, volunteers, Board members, or the public;
- Harassment, retaliation, or discrimination stemming from reporting a concern.
The actions above shall be referred to as “Reportable Activities.”
BBBSEN strictly prohibits any form of retaliation, harassment, or discrimination against anyone who reports a concern in good faith. Retaliation in any form will not be tolerated, and violations of this Policy may lead to disciplinary actions, including termination of employment or severing relationships with Board members, suppliers, or other stakeholders.
Complaints made without good faith, or with malicious intent, will also be treated as serious offenses and may result in disciplinary actions.
Procedure for Making a Complaint
To report a concern or a Reportable Activity, individuals should complete the Complaint Report Form provided in Appendix 1. Once completed, the form should be submitted to the Chair of the Board, who is responsible for investigating complaints and taking appropriate actions.
- If the complaint concerns an employee (other than the Executive Director) or a consultant, the Board Chair will refer the matter to the Executive Director.
- If the complaint concerns the Chair of the Board, the complaint should be forwarded to the Board Executive Committee or the Executive Director for investigation.
While complainants are permitted to remain anonymous, providing contact information will facilitate a more thorough investigation. Whether or not the complainant chooses to identify themselves, all information will be treated with strict confidentiality, with the matter discussed only to the extent necessary to conduct a fair and thorough investigation.
To assist in the investigation, the complainant should provide as much detail as possible, including:
- The nature of the Reportable Activity;
- The date and location of the incident(s);
- Names and titles of individuals involved;
- Any additional relevant details.
Investigation and Resolution of Complaint
The individual receiving the complaint (the “Investigator”) is responsible for ensuring that the matter is investigated promptly and thoroughly. They will work to resolve the issue and, where appropriate, will report the resolution to the complainant. Under no circumstances will the investigation or resolution be handled by anyone identified in the complaint or deemed inappropriate by the Investigator.
The Investigator will ensure that the investigation is conducted fairly and impartially, taking the necessary steps to address the concern raised. Where required, disciplinary or legal action may be initiated based on the findings of the investigation.