Whistleblower Policy
1. Statement of Purpose In accordance with industry best practices resulting from the Sarbanes-Oxley Act of 2002, this policy establishes a process for the prompt resolution of reports or complaints of improper or ill-advised behavior regarding NHPF's business, personnel, accounting and internal control practices and Policies (Improprieties). It further makes clear the Foundation's strong "no tolerance" stance for retaliatory behavior.
2. Scope and Applicability This policy applies to all NHPF staff, officers and members of the Board of Trustees.
3. Policy Implementation This policy is part of the Foundation's Business Conduct and Ethics Policy. Both Policies are required to be reviewed annually by all employees and officers. The Foundation has designated the Audit Committee Chair to be the recipient of al l reports filed under this Policy. The Chair will coordinate with the Audit Committee to develop a preliminary plan of investigation, potential implications, and possible solutions. Final resolution will be carried out by the Foundation after consultation with NHPF's CEO and CFO.
4. Control Objectives This policy and its process ensure that:
• Employees who become aware of Improprieties report them immediately. • Employees who communicate Improprieties are protected by confidentiality and anonymity to the extent reasonably possible. • Complaints and the resolution thereof will be handled by an individual who is independent of NHPF's senior management -- the Chair of the Board of Trustee's Audit Committee. • Anyone filing a written complaint or verbal complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. 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. • Employees understand and adhere to NHPF's Business Conduct and Ethics Policies.
5. Policy Statements 5.1
Reporting. Each employee has a responsibility to promptly report any suspected misconduct, illegal activities or fraud, including any questionable accounting, internal accounting controls and auditing matters, or other violations of federal and state laws or of our Business Conduct and Ethics Policy in accordance with the provisions of this pol icy.
Entity Level Policy: NHPF -02 Effective Date: ____________ Version 2.0
Powered by FlippingBook