Introduction
ANSI and Workcred encourage employees and contractors to promptly raise concerns about fairness, quality, or potential violations of law or ANSI policy. ANSI and Workcred work to foster an environment in which employees and contractors feel safe raising concerns, seeking guidance and identifying areas for improvement. The purpose of this Whistleblower Policy is to provide our employees and contractors with a mechanism for doing that.
Statement of Policy
Misunderstandings or conflicts can arise in any organization. Occasionally, an employee may feel that they have not been treated fairly, a mistake has been made in the administration of ANSI’s policy, or that ANSI or ANSI’s employees have engaged in conduct that may have violated applicable law. To ensure effective work relations and to enable ANSI to address potential problems, it is important that such matters be reported and resolved before serious problems develop. Except for situations regarding sexual or other harassment or illegal activities (see note below), if a situation exists or persists that you believe is detrimental to you or to ANSI, you should follow the procedures described here for bringing your complaint to the attention of management.
Step One: Discussing the problem with your immediate supervisor is encouraged as a first step. It has been ANSI’s experience that most problems can be resolved by discussing them. If, however, you do not believe a discussion with your supervisor is appropriate, you may proceed directly to Step Two.
Step Two: If your problem is not resolved after discussion with your supervisor or if you feel discussion with your supervisor is inappropriate, you are encouraged to request a meeting with either the Director or Vice President in charge of your department. In an effort to resolve the problem, that Director or Vice President will consider the facts, conduct an investigation, and may also review the matter with the Human Resources Department and, as appropriate, the Sr. Vice President & General Counsel. You should prepare on your own time a written outline of your concerns, the name of your immediate supervisor, the date on which you and your supervisor met to discuss the problem (if you did so), and your interpretation of the decision reached by your supervisor (if any) and submit the same to the appropriate Director or Vice President.
Step Three: If you are not satisfied with the decision of the Director or Vice President, or if you feel discussion with the Director or Vice President is inappropriate, and wish to pursue the problem or complaint further, you may submit a written summary of your concerns and request that the matter be reviewed by the Human Resources Department or the Sr. Vice President & General Counsel. In such a case, Human Resources andthe General Counsel’s Office, after a full examination of the facts (which may include a review of the written summary of your statement, discussions with all individuals concerned, and a further investigation if necessary), will, as appropriate, advise you of their decision within fifteen working days. That decision shall be final.
ANSI does not tolerate any form of retaliation against employees availing themselves of this procedure. No employee who in good faith reports any action or suspected action taken by or within the organization that is illegal, fraudulent or in violation of any adopted policy of ANSI will suffer intimidation, harassment, discrimination, adverse employment consequences or other retaliation. The procedure should not be construed, however, as preventing, limiting, or delaying ANSI from taking disciplinary action up to and including termination, against any individual in circumstances (such as those involving problems of overall performance, conduct, attitude, or demeanor) when ANSI deems disciplinary action appropriate. Further, the filing of a complaint under this policy does not provide employees a guarantee of employment for any specified duration, nor does it in any way alter the at-will nature of employment with ANSI.
Note: Notwithstanding this whistleblower policy, all complaints relating to sexual or other harassment or discrimination should be reported immediately to the whistleblower’s supervisor or any other member of ANSI management, the President & CEO, the Sr. Vice President & General Counsel, Associate General Counsel, or the Human Resources Department as soon as possible.
Furthermore, should you become aware of any other violation of any federal, state, or local laws or regulations or rules by ANSI or any employee acting on ANSI’s behalf, or of facts that could be alleged to constitute such a violation, you must make a good faith effort to advise the Sr. Vice President & General Counsel of any such violation or facts before disclosing the violation or facts to any other person, entity, or agency, or taking any action with respect thereto, to enable ANSI to investigate and take any appropriate steps with respect thereto.
It is the responsibility of ANSI and Workcred (“ANSI”) directors, members and volunteers to report possible violations of applicable laws or policies in accordance with this whistleblower policy.
Purpose of Policy
The purpose of this Whistleblower Policy is to provide ANSI directors, members, volunteers and other participants with a confidential mechanism for reporting suspicious activities or conduct believed to be illegal, unethical, or in violation of the standards of conduct adopted by ANSI.
No Retaliation
No ANSI director, member or volunteer who in good faith reports any action or suspected action taken by or within ANSI that is illegal, fraudulent or in violation of any ANSI policy shall suffer intimidation, harassment, discrimination or other retaliation. Anyone who retaliates against someone who has reported a violation of this Policy in good faith is subject to discipline up to and including termination of employment.
Procedures for Reporting a Violation
All violations or suspected violations of relevant laws or policies should be reported verbally or in writing to ANSI’s General Counsel, who in turn will refer such violations to the ANSI Audit Committee for appropriate action. If the complainant is not comfortable speaking with ANSI’s General Counsel or is not satisfied with the response received, the issue may be raised or escalated directly to the Chair of the Audit Committee, the ANSI President or the ANSI Board Chair.
Confidentiality
Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
Administrator
This Whistleblower Policy shall be administered by ANSI’s General Counsel and the ANSI Audit Committee. ANSI’s General Counsel will notify the complainant and acknowledge receipt of the reported violation or suspected violation within a reasonable time. All reports will be promptly reviewed and appropriate corrective action will be taken as warranted.
Standards of Conduct Adopted by ANSI
ANSI’s Codes of Conduct, available here, sets forth guiding principles for professional conduct and integrity for our employees, contractors and volunteers. If a complaint brought under this Whistleblower Policy relates to conduct covered by one of the Codes of Conduct, it will be handled under the procedures set forth in the applicable Code. Otherwise, the General Counsel, in consultation with the Audit Committee, will approve a course of action for resolving the complaint.
Distribution/Publication of the Whistleblower Policy
This Whistleblower Policy will be distributed to all directors and members and will be posted to a public page on ANSI’s website. It will be reviewed and evaluated for effectiveness periodically by the ANSI Board of Directors.
