Whistleblower Policy: Internal Reporting and Anti-Retaliation
Cary Academy requires directors, officers, and employees to observe high standards of business and professional ethics in the conduct of their duties and responsibilities. As employees and representatives of the School, employees must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws, regulations, and School policies.
Reporting Responsibility
It is the responsibility of all directors, officers and employees to comply with Cary Academy’s policies and to report any violations or suspected violations of Cary Academy’s policies in accordance with this Whistleblower policy. Directors, officers, and employees are also required to comply with applicable federal and state law and to report violations or suspected violations of applicable law, including but not limited to the Occupational Safety and Health Act, federal and state environmental laws, federal securities laws, and the Affordable Care Act, in accordance with this policy. This policy is intended to encourage and enable employees and others to raise serious concerns within the organization prior to seeking resolution outside the School.
Before an employee discloses a violation outside the School, the employee is urged to provide notice to the School in accordance with this policy to allow the School the reasonable opportunity, when appropriate, to take corrective action.
The School expects all employees to report any suspected criminal activity regardless of the identity or position of the employee involved.
Cary Academy suggests that officers, directors, and employees initially report violations or suspected violations to someone who can address them properly. In most cases, an employee’s supervisor is in the best position to address such matters. However, if you are not comfortable speaking with your supervisor or are not satisfied with your supervisor’s response, you are encouraged to speak with the Head of School, the Chief Financial Officer, or any other Division Head whom you are comfortable approaching. Supervisors and Division Heads are required to report suspected misconduct to the Treasurer of the Cary Academy Board of Directors who serves as Cary Academy’s Compliance Officer for purposes of this policy and who has specific and exclusive responsibility to investigate all reported violations. For suspected fraud, or when you are not satisfied or uncomfortable, individuals should contact the Compliance Officer directly. Officers and directors are encouraged to speak to the Chair of the Board of Directors or another officer or director, as appropriate. The notice should specify in reasonable detail the nature of violations or suspected violations and the persons involved. The earlier a concern is expressed, the easier it should be to act and the more likely relevant information will not have become stale.
The Compliance Officer is responsible for investigating and resolving all reported complaints and allegations concerning fraudulent or dishonest conduct and, at his/her discretion, shall advise the Chair of the Board of Directors, the Head of School, and/or the Finance Committee. The Compliance Officer is required to report at least annually to the Finance Committee on compliance activity. The Finance Committee of the Board of Directors shall address all reported concerns or complaints regarding organizational 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. The Compliance Officer will notify the sender (if known) and acknowledge receipt of the reported misconduct or suspected misconduct within ten business days. All reports will be promptly investigated, and appropriate disciplinary and/or legal action will be taken if warranted by the investigation.
No Retaliation
No director, officer, or employee who, in good faith, reports a violation of the School’s policies or applicable law shall suffer harassment, retaliation, or adverse employment consequences. It is a violation of this policy for anyone, whether acting alone or on behalf of the School, to retaliate against any individual for making a good faith report in accordance with this policy. An employee who retaliates against someone who has reported a violation in good faith may be subject to discipline up to and including termination of employment or office.
Acting in Good Faith
Anyone reporting a violation or suspected violation of the School’s policies or applicable law must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Employees found to have knowingly made false accusations may be subject to disciplinary action up to and including termination of employment or office.
Confidentiality
While Cary Academy encourages the reporting individual to reveal his or her name to facilitate investigation, concerns reported anonymously will be investigated to the fullest extent possible under the circumstances.
Upon receipt of a report, Cary Academy will promptly conduct a thorough investigation in such a way as to maintain the confidentiality of the individuals involved to the extent possible under the circumstances.