God's Love We Deliver
166 Avenue of the Americas
New York, NY 10013
God's Love We Deliver
Effective January 2014
The directors, executives, officers, employees and volunteers of God's Love We Deliver are expected to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees, representatives of the Agency and volunteers must practice honesty and integrity in fulfilling our responsibilities and complying with all applicable laws and regulations. The Whistleblower Policy will serve to safeguard these high standards and personal ethics.
The matters which should be reported under this policy include, but are not limited to any action or suspected action that is illegal or improper such as:
• accounting or auditing irregularities;
• misuse of our assets;
• gross mismanagement of a government contract or grant;
• gross waste of government funds;
• an abuse of authority relating to a government contract or grant;
• a substantial and specific danger to public health or safety; or
• any other suspected regulatory, compliance, or ethics related issues, concerns or violations (including the competition for or negotiation of a government contract or grant).
Any suspected violations of our Agency's applicable human resources policies, problems with co-workers or managers, or for reporting issues related to alleged employment discrimination or sexual or any other form of unlawful harassment should be reported in accordance with the EEO policies stated in the Employee Guide.
2. Procedure For Reporting Concerns
It is the responsibility of all executives, officers, employees and volunteers to report violations or suspected violations of high business and ethical standards and/or applicable legal requirements in accordance with this Whistleblower Policy.
Individuals should share their questions, concerns, suggestions or complaints regarding suspected violations with someone who can address them properly. Volunteers should speak with a Volunteer Services Specialist regarding any concerns. If a volunteer is not comfortable speaking with Volunteer Services Specialist or is not satisfied with the response received, the volunteer can speak with the Director of Volunteer Services or anyone else in senior management the volunteer is comfortable approaching. For employees, in most cases, an employee's supervisor is in the best position to address an area of concern. However, if an employee is not comfortable speaking with his/her supervisor, or is not satisfied with the supervisor's response, the employee is encouraged to speak with anyone in senior management whom the employee is comfortable approaching. Senior managers are required to report suspected violations to either the CEO or Chair of the Board of Directors. If executive staff are not comfortable reporting suspected violations to the CEO or Chair, they must then report suspected violations to the Chair of the Audit Subcommittee of the Finance Committee of the Board.
3. Protection of Whistleblowers
- No Retaliation - No director, executive, officer, employee or volunteer who in good faith reports any action or suspected action taken by or within God's Love We Deliver that is illegal, fraudulent or in violation of any adopted God's Love We Deliver policy shall suffer any intimidation, harassment, discrimination or other retaliation or, for employees, any adverse employment consequence. An individual who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within our Agency prior to seeking resolution outside our Agency.
- Confidentiality - Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. Concerns expressed anonymously will be investigated to the extent possible. Individuals should be aware, however, that anonymity could become an obstacle to full review and resolution of a concern, and that they may, therefore, be asked to provide certain additional identifying details in order to conduct a thorough investigation of their allegations.
4. Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation of the ethical and legal standards noted above must act in good faith and have reasonable grounds for believing the information disclosed may indicate a violation of such standards. 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 punishable by discipline up to and including termination.
5. Administration of Policy: Responsibilities of the Chair of the Board and/or Chair of the Audit Subcommittee
The CEO is responsible for the administration of this policy and must report suspected violations to the Executive Committee of the Board. The responsibilities for investigating the complaint are listed below.
Any Report that is made directly to senior management or to any member of the Board of Directors, whether openly, confidentially or anonymously, will be promptly reported to either one of Board Chair or to the Chair of the Audit Subcommittee. That person will serve as the "director" of the investigation. S/he will receive, retain, investigate and act on all reported complaints and concerns related to questionable financial practices, compliance with legal and regulatory requirements, other ethics related issues and retaliation against employees who report suspected violations.
The director of the investigation will notify the person who made the complaint – if his/her identity is known – and acknowledge receipt of the Report within seven days.
At the discretion of director of the investigation, responsibilities created by this policy may be delegated to either the Board Chair, to the Chair of the Audit Subcommittee, to the entire Audit Subcommittee or to senior management. The director will have discretion to consult with any member of senior management who is not the subject of the allegation and may have appropriate expertise to assist.
If the director of the investigation determines that senior management should investigate the Report, s/he will notify the CEO of God's Love We Deliver in writing of that conclusion. Senior management will thereafter promptly investigate the Report and will report the results of its investigation, in writing, to the director of the investigation. Senior management will be free in its discretion to engage outside auditors, counsel or other experts to assist in the investigation and in the analysis of results.
If the director of the investigation determines that s/he or the Audit Subcommittee should investigate the Report, s/he will promptly determine what assistance, if any, is needed in order to conduct the investigation. Such assistance may include the creation of an ad hoc committee to advise in conducting the investigation. The director of the investigation will be free in its discretion to engage outside auditors, counsel or other experts to assist in the investigation and in the analysis of results.
The director of the investigation will inform the Board of Directors of the receipt of a Report, and the actions taken by him/her, when appropriate. The director is not required to inform the Board of Directors of a Report prior to the conclusion of an investigation, if doing so would be likely to jeopardize the integrity of the investigation. The approval of the Board of Directors is not required for the director of the investigation to investigate a Report or to direct senior management to investigate a Report.
God's Love We Deliver will retain for a period of seven years all records relating to any Report and investigation.
For Fiscal Year 2014, the contacts are as follows and can be reached at 212.294.8100:
CEO, Karen Pearl
Board Chair, Scott Bruckner
Chair of the Audit Subcommittee, Mark Lanspa