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Whistleblower Policy

Download the Whistleblower Policy PDF

Scope

Conner Prairie full-, part-time and seasonal non-exempt staff members and volunteers.

Policy Statement

Conner Prairie requires officers, directors, leadership and employees to observe the highest standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of Conner Prairie, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Reason for Policy

This policy is intended to encourage and enable employees and others to raise serious concerns internally so that Conner Prairie can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, leadership, employees and volunteers to report concerns about violations of Conner Prairie’s code of ethics and suspected violations of law and regulations that govern our operations.

Procedures

Conner Prairie has an open door policy and suggests that employees and volunteers share their questions, concerns, suggestions and complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with the Director of Human Resources or the designated Compliance Officer. Conner Prairie’s Compliance Officer is the chair of the audit committee.

Conner Prairie leaders are required to report complaints or concerns about suspected ethical and legal violations in writing to Conner Prairie’s Human Resource Director and/or Compliance Officer who have the responsibility to investigate all reported complaints. Employees with complaints may also submit their concerns in writing directly to their supervisor, Director of Human Resources, President and Chief Executive Officer or Compliance Officer.

Confidential Email Reporting:

Conner Prairie has also established a confidential email outside of the organization for reporting ethical or compliance concerns. If you are uncomfortable bringing your issue to your supervisor, the Human Resources Director, President/CEO or the Compliance Officer, the following confidential email and contact can be utilized: compliancehotline@connerprairie.org

The compliance hotline email is monitored by an assigned outside, non-employee who is appropriate to respond to these types of issues.

Conner Prairie’s Compliance Officer in collaboration with the Director of Human Resources is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Compliance Officer and/or Director of Human Resources will advise the President and Chief Executive Officer of all complaints and their resolution. The Compliance Officer will report at least annually to the audit committee on compliance activity relating to accounting or alleged financial improprieties.

Additionally, Conner Prairie’s Compliance Officer shall immediately notify the audit committee of any concerns or complaints regarding corporate accounting practices, internal controls or auditing and work with committee until the matter is resolved.

Definitions

Acting in Good Faith: Anyone filing a written 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 are not substantiated and are proven to have been made maliciously or knowingly false will be viewed as a serious disciplinary action.

Retaliation: No employee who in good faith reports a violation will suffer harassment, retaliation or adverse employment consequence. 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. All reports of retaliation should be brought to the immediate attention of the Human Resources Director. The right of a whistleblower for protection against retaliation does not extend to immunity for any personal wrongdoing that is alleged and investigated.
This policy is intended to encourage and enable employees and others to raise serious concerns within Conner Prairie prior to seeking resolution outside of the organization.

Confidentiality: Violations or suspected violations may be submitted in writing 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.

Handling Reported Violations: Conner Prairie’s Compliance Officer will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation within five (5) business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.


Key Whistleblower Laws

  • False Claims Act
  • Dodd-Frank Act
  • Tax Relief and Health Care Act of 2006 (IRS Whistleblower Law)
  • Sarbanes-Oxley Act of 2002
  • Other Industry Specific Acts (not listed)