If you observe what you believe to be wrongful conduct, you have the right and the duty to report it without fear of retaliation.

DEFINITION OF WRONGFUL CONDUCT

Wrongful conduct includes serious improper actions that could impact First Circle’s integrity and operation. Examples include, but are not limited to:

• Violations of federal, state, or municipal law
• Sexual harassment or other forms of unlawful harassment or discrimination
• Use of First Circle resources, funds, or property for personal gain
• Using, or permitting sale, solicitation or use of narcotics or other illegal drugs, or prescription medication without a prescription, while on the job
• Being under the influence of alcohol or illegal drugs while at work
• Inappropriate language or communication between families, children, or staff

REPORTING WRONGFUL CONDUCT

If you observe or are told something you believe to be wrongful conduct, you are responsible for reporting it to the director, executive director, or HR manager.  If the wrongful conduct implicates the HR manager, you should report it to the executive director. If the wrongful conduct implicates the director, or if you are not satisfied with the director’s response, you may report the issue to the HR manager or executive director or president. Your report should include specific details about the incident(s) with dates and names of individual(s) involved.

GOOD FAITH

Acting in good faith means that you have reasonable grounds for believing what you’ve witnessed or heard indicates wrongful conduct. Any allegations that prove to have been knowingly false will be viewed as a serious offense and could result in disciplinary action.

NO RETALIATION

No one who reports wrongful conduct in good faith will suffer retaliation (meaning termination, discipline, refusal to hire or promote) by any First Circle administrator. Any employee, including the director, who retaliates against you for reporting in good faith suspected wrongful conduct is subject to discipline up to and including termination of employment. If you feel you have been subject to retaliation, please report the specific retaliation in writing to the person you submitted your initial report to for follow-up.

CONFIDENTIALITY

Any reports of suspected wrongful conduct can be made in confidence without fear of retaliation. Reports of suspected wrongful conduct will be kept confidential, except to the extent necessary to conduct a complete and fair investigation.

HANDLING OF REPORTED WRONGFUL CONDUCT

The person (director, HR manager or executive director) to whom you submitted the report of suspected wrongful conduct will acknowledge receipt of your report within 5 business days. All reports will be promptly investigated. Appropriate corrective action will be taken if warranted.  You will be informed when the investigation has concluded. However, the extent to which you are informed of the findings may be subject to the advice of First Circle’s legal counsel.