Second Harvest is committed to the highest possible standards of ethical, moral, and legal conduct. Consistent with this commitment, our policy aims to provide an avenue for employees to raise concerns about suspected misconduct, dishonesty, or fraud, and to provide reassurances that they will be protected from reprisals or victimization for whistleblowing in good faith.
Reporting
It is the responsibility of every employee to report concerns relating to suspected misconduct, dishonesty, or fraud. Such concerns might include:
- Theft, fraud, waste, or abuse of resources
- Any form of dishonesty
- Harassment or discrimination
- Accounting or financial irregularities
- On-the-job drug or alcohol abuse
- Violence or threatening behavior
- Violations of laws, regulations, policies, or procedures
- Conflicts of interest
- Health and safety concerns
Such concerns should be immediately shared with HR or a member of the Executive Team. If you do not feel comfortable or safe reporting to someone within the company, Second Harvest provides an anonymous channel through which confidential reports may be made to the Audit Committee. The Audit Committee is comprised of board and community members tasked with overseeing the financial integrity of the food bank. You should report your concerns to our Whistleblower Hotline: 831-274-9481. You can also send an email to [email protected]. Emails and phone calls are received directly by the Chair of the Audit Committee.
Following receipt of any complaints submitted, the Audit Committee Chair or his/her designee will investigate each matter and take corrective and disciplinary actions where appropriate. The Audit Committee may enlist committee members, employees of Second Harvest, and/or outside legal assistance, auditing or other advisors, as appropriate, to conduct any investigation of complaints regarding financial reporting, accounting, internal accounting controls, auditing matters, or any other form of misconduct, dishonesty, or fraud. In conducting any investigation, the Audit Committee will use reasonable efforts to protect the confidentiality and anonymity of the complainant.
Assuming the complainant gave a method for contact, they will receive an acknowledgement that the concern was received and that the matter was dealt with.
The communication will indicate whether the concern will be pursued and, if not, why not. If the issue is to be investigated, the communication will give an estimate of time to review the concern, followed by another communication that details the outcome of any investigations.
No Retaliation
No employee who in good faith reports a violation shall suffer harassment, retaliation, or adverse employment consequences. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This policy is intended to encourage and enable employees and others to raise concerns within the organization prior to seeking resolution outside the organization.
Additionally, no employee shall be adversely affected because s/he refuses to carry out a directive which, in fact, constitutes corporate fraud, or is a violation of state or federal law.
Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. Every effort will be made to protect the complainant’s identity.
That said, employees are encouraged to put their names to allegations because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified. Concerns expressed anonymously will be investigated, but consideration will be given to:
- The seriousness of the issued raised
- The credibility of the concern
- The likelihood of confirming the allegation from attributable sources
Anyone filing a complaint must be acting in good faith and have reasonable grounds for believing the information disclosed indicates misconduct, dishonesty, or fraud. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.