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Whistle Blower Policy
Baptist Healing Trust is committed to the creation of a compassionate culture which includes the highest possible standards of ethical, moral and legal business conduct. We will conduct business fairly, impartially, in an ethical manner and in complete compliance with the law. Our business conduct must be always guided by the highest level of integrity and open communication when dealing with our employees, Trustees, Community Board Members, consultants, volunteers, and eligible 501(c)(3) applicant organizations. In line with this commitment and Baptist Healing Trust’s commitment to open communication, an ethics policy and hotline have been established to provide an avenue for Baptist Healing Trust stakeholders to raise concerns. It is our intent through this policy to establish reassurance that any complainant will be protected from reprisals or victimization for whistle blower claims reported in good faith. We have established a Whistle Blower Hotline through Lighthouse Services, Inc. for the specific purpose of reporting fraud, unlawful, unethical and other types of improper behavior. This hotline is NOT a substitute for routine communications within our organization between employees and their supervisors and managers, particularly as to workplace duties. This Whistle Blower Hotline is an additional communication tool for specific types of situations, and it is provided because we believe that it is a good business practice to do so.
For more detail on the BHT Whister Blower Policy, please follow this link: www.lighthouse-services.com/healingtrust
WHISTLE BLOWER HOTLINE PROCEDURES
This policy applies to all Baptist Healing Trust employees, including part time, temporary and contract employees, Trustees, Community Board Members, consultants, volunteers, and eligible 501(c)(3) applicant organizations.
Baptist Healing Trust is committed to the highest possible standards of ethical, moral and legal business conduct. In line with this commitment and Baptist Healing Trust’s commitment to open communication, this policy aims to provide an avenue for stakeholders to raise concerns and reassurance that they will be protected from reprisals or victimization for whistleblowing in good faith. If an employee feels that their anonymity is not required then they should follow Baptist Healing Trust’s existing grievance procedure.
The whistleblowing policy is intended to cover serious concerns that could have a large impact on Baptist Healing Trust, such as actions that:
May lead to incorrect financial reporting;
Are not in line with company policy, including the Code of Business Conduct; or
Otherwise amount to serious improper conduct.
Regular business matters that that do not require anonymity should be directed to the employee’s supervisor and are not addressed by this policy.
Harassment or Victimization
Harassment or victimization of the complainant will not be tolerated.
Every effort will be made to protect the complainant’s identity. Please note that the information provided by you may be the basis of an internal and/or external investigation into the issue you are reporting and your anonymity will be protected to the extent possible. However, your identity may become known during the course of the investigation.
The policy allows employees to remain anonymous at their option. Concerns expressed anonymously will be investigated, but consideration will be given to:
The seriousness of the issue raised;
The credibility of the concern; and
The likelihood of confirming the allegation from attributable sources.
Malicious allegations may result in disciplinary action.
The whistleblowing procedure is intended to be used for serious and sensitive issues.
Serious concerns relating to financial reporting, unethical or illegal conduct, should be reported in either of the following ways:
Through the Toll Free Hotline: English speaking
Spanish speaking North America: (800) 216-1288 (from
E-mail: email@example.com (must include Baptist Healing Trust’s name with report)
Fax alternative for written documents: 215-689-3885 (must include Baptist Healing Trust’s name with report)
Callers to the Hotline will have the ability to remain anonymous if they choose. Please note that the information provided by you may be the basis of an internal and/or external investigation into the issue you are reporting and your anonymity will be protected to the extent possible by law. However, your identity may become known during the course of the investigation. Complaints are submitted by Lighthouse to Baptist Healing Trust or its designee, and may or may not be investigated at the sole discretion of the Baptist Healing Trust.
Employment-related concerns should continue to be reported through normal channels such as the immediate supervisor, the President and CEO, or designee. Should the offending conduct involve the immediate supervisor, including the President and CEO, the employee should bring the matter to the attention of the Chair of the Board, Chair of the Audit Committee, and the Chair of the HR and Compensation Committee. Any other complainants should use the reporting means noted above.
The earlier a concern is expressed, the easier it is to take action.
Although the complainant is not expected to prove the truth of an allegation, the complainant needs to demonstrate sufficient grounds for concern.
HOW THE COMPLAINT WILL BE HANDLED:
The Audit Committee shall address all reported concerns. The Trust representatives receiving the complaint will notify the entire Audit Committee as soon as possible after receipt of any such reported concern. If the complainant provides contact information, the Chair of the Audit Committee or appropriate Board representative will notify the complainant and acknowledge receipt of the concern within five business days. If the complaint is filed anonymously, the Chair of the Audit Committee or appropriate Board representative will work through the whistleblower hotline feedback process for communicating with anonymous claimants.
All reports will be promptly investigated by the Audit Committee, and appropriate corrective action will be recommended to the Board, if warranted by the investigation. In addition, action taken must include a conclusion and/or follow-up with the complainant, unless the complaint is filed anonymously, for complete closure of the concern.
The Audit Committee must receive Board approval to retain outside legal counsel, accountants, private investigators, or any other resource deemed necessary to conduct a full and complete investigation of the allegations.
Initial inquiries will be made to determine whether an investigation is appropriate, and the form that it should take. Some concerns may be resolved by agreed action without the need for investigation.
Report to Complainant
Whether reported to Baptist Healing Trust personnel or through the hotline, the complainant will be given the opportunity to receive follow-up on their concern:
Acknowledging that the concern was received;
Indicating how the matter will be dealt with;
Giving an estimate of the time that it will take for a final response;
Telling them whether initial inquiries have been made;
Telling them whether further investigations will follow, and if not, why not.
The amount of contact between the complainant and the body investigating the concern will depend on the nature of the issue, the clarity of information provided, and whether the complainant remains accessible for follow-up. Further information may be sought from the complainant.
Subject to legal constraints the complainant will receive information about the outcome of any investigations.
Baptist Healing Trust reserves the right to modify or amend this policy at any time as it may deem necessary.