All reports will be taken seriously and addressed promptly with discretion and candor. All d iscussions and documentation regarding reports will be kept in strict confidence to the extent appropriate or permitted by pol icy or law. Staff should communicate reports of Improprieties directly to the Audit Committee Chair. Chair will immediately communicate the nature of the report to the Audit Committee along with a preliminary plan of investigation, potential implications, and possible solutions. The Chair will complete the investigation and issue to the Committee a written report with recommendations within 30 days or an agreed upon period. The Chair, after consultation with NHPF's CEO and CFO, will issue a final disposition with instructions to the CEO and CFO for implementation. 5.2 Receiving and Investigating Reports. Upon receipt of a report of Impropriety, The 5.3 Retaliation. NHPF will not tolerate any retaliation against any employee that reports an Impropriety or cooperates in an investigation. Any officer or employee determined to have engaged in retaliatory behavior will be subject to discipline. If an employee believes he or she has been subjected to any behavior that violates this Pol icy, he or she may file a complaint with the Audit Committee Chair. 6. Oversight andMonitoring Legal Counsel for NHPF will maintain copies of all reports filed under this Policy, including all documents obtained or created in connection with any investigation and the final disposition for a period of 5 years.
7. Policy Review This Pol icy will be reviewed annually by the Board of Trustees with updates made as necessary.
8. Policy Governance
Policy Name: Policy Type: Policy Identifier: Version Number: Policy Author: Policy Owner: Date Approved: Effective Date: Latest Revision Policy Approver(s): Frequency of Policy Location: Supersedes Policy: Retirement Date:
Whistleblower Policy
Entity Level NHPF-02
2.0
Richard Burns, CEO
Ralph Boyd, Chair -NHPF Board of Trustees
NHPF Board of Trustees
April 22, 2019
Annually
TBD NIA NIA
Entity Level Policy: NHPF -02 Effective Date: ____________ Version 2.0
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