Cataleya Whistelblower Policy V1.0

Table of Contents

1. Introduction

In keeping with the policy of maintaining the highest standards of conduct and ethics, Cataleya will investigate complaints of suspected wrongdoing occurring within its programs and services; fraudulent or dishonest use or misuse of its resources or property; violations of agency policy; and violations of local, state, and federal law (each, “Suspected Wrongdoing”). Employees, contractors, board members, volunteers, clients, and community members are encouraged to report all suspected wrongdoing under the procedures set forth below.

This policy supplements, and does not replace, Cataleya’s unlawful harassment and discrimination policy and/or any other complaint resolution/grievance policy, and any procedures required by law, regulation, or funding source requirements

1.1 Objective

This policy supplements, and does not replace, Cataleya’s unlawful harassment and discrimination policy and/or any other complaint resolution/grievance policy, and any procedures required by law, regulation, or funding source requirements.

2. Procedure

2.1 Good Faith

A person reporting concerns under this policy must act in good faith and have reasonable grounds for believing that the information reported indicates that Suspected Wrongdoing has occurred. A person who makes an allegation maliciously or with good reason to believe that the allegation was false will be subject to disciplinary action, up to and including termination of employment.

2.2 Reporting

A person’s concerns about Suspected Wrongdoing should be reported to his/her immediate supervisor. If a person is not comfortable reporting to his/her supervisor, concerns may be reported to the Cataleya’s Director of Human Resources the Cataleya’s Executive Director, or the designated compliance officer.

If the Suspected Wrongdoing concerns a board member or the Executive Director, the report should be made to the Chairperson of the Cataleya’s Board of Directors. If the Suspected Wrongdoing concerns the Chairperson of the Board of Directors, the report should be made to the Chairperson of the Board’s Audit Committee.

Reports of Suspected Wrongdoing should contain the names of the individuals involved, dates, and a description of the actions believed to be Suspected Wrongdoing. At no time should an individual who has reported or is considering reporting Suspected Wrongdoing undertake an independent investigation into the matter to obtain additional information.

2.3 Confidentiality

The Cataleya encourages anyone reporting Suspected Wrongdoing to identify himself or herself when making a report to facilitate the investigation of the Suspected Wrongdoing. However, reports may be submitted anonymously by mailing a written statement to info@cataleya.com. Reports of Suspected Wrongdoing will be kept confidential to the extent possible, but confidentiality cannot be guaranteed in light of the need to conduct an adequate investigation, comply with all applicable laws, and cooperate with law enforcement.

2.4 Investigation

Reports of Suspected Wrongdoing will be promptly reviewed and analyzed by Cataleya’s designated compliance officer. Appropriate corrective action will be taken if warranted by the investigation, and findings may be communicated to the reporting person.
The Whistle Blowing Policy covers the following: –

• conduct which is an offense or a breach of law, e.g. fraud, corruption or theft
• disclosures related to miscarriages of justice
• health and safety risks, including risks to patients/visitors as well as other employees
• damage to the environment, e.g., green issues
• Verbal, sexual, or physical abuse of patients, or other unethical conduct/behavior
• discrimination on grounds of sex, race or disability or religion
• poor clinical practice
• malpractice
• professional misconduct
• nepotism

2.5 Checklist

To assist us in assessing or investigating your concerns, it would be helpful if you could be as clear as possible with the details. As a minimum we need to understand the following:

• Date(s) of incident(s)
• Type of incident
• Description of incident(s)/details of concerns
• Where did it happen?
• Who has been involved?
• If possible, explain how you think the matter may be best resolved or start thinking about it in preparation for any meetings you may be required to attend (if you have shared your identity).
If you feel comfortable sharing your identity then please provide us with your name, your work location, and contact details.