Whistleblower Policy

General

The Alliance for Continuing Medical Education (Alliance) requires directors, officers, volunteers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the Alliance, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility
It is the responsibility of all directors, officers and employees to report violations or suspected violations of any applicable laws or regulations by Alliance personnel in accordance with this Whistleblower Policy.

No Retaliation

No director, officer or employee who in good faith reports a violation shall 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. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the Alliance prior to seeking resolution outside the Alliance.

Reporting Violations

The Alliance suggests that employees share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor is in the best position to address an area of concern. However, if an employee is not comfortable speaking with a supervisor or not satisfied with the supervisor’s response, the employee is encouraged to speak with anyone in management. Supervisors and managers are required to report suspected violations to the Alliance’s Compliance Officer, who has specific responsibility to investigate all reported violations. For suspected fraud, or when not satisfied or uncomfortable with contacting the management, individuals should contact the Alliance’s Compliance Officer directly.

Volunteers should report violations directly to the Compliance Officer.

Contact information for reporting violations may be found on the Alliance Website () under Membership Networking and Membership Directory.

Compliance Officer

The Alliance Secretary/Treasurer acts as Compliance Officer and is responsible for investigating and resolving all reported complaints and allegations concerning violations and, at his/her discretion, shall advise the Finance Committee or the Board of Directors. The Compliance Officer has direct access to the Finance Committee and the Board of Directors and is required to report to the Finance Committee at least annually on compliance activity.

Accounting and Auditing Matters

The Finance Committee shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The Compliance Officer shall immediately notify the Finance Committee of any such complaint and work with the committee until the matter is resolved.

Acting in Good Faith

Anyone filing a 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.

Confidentiality

Violations or suspected violations may be submitted 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 of Reported Violations

The Compliance Officer will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days, unless the submission of the violation is anonymous. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. 




Adapted From National Council of Nonprofit Associations

Approved by the Board of Directors on October 30, 2004