Purpose

To ensure Recovery Works staff and executives hold themselves to the highest standards of business and professional conduct and to create and maintain a safe environment for the reporting of violations of these standards.

Policy

A clear and forthright “whistleblower” policy exists and is communicated to all staff, making it safe for them to report violations of Recovery Works standards of conduct.

Procedure

Recovery Works requires that all staff members, directors and officers observe the highest standards of business and professional ethics in the conduct of their duties and responsibilities. All staff members and representatives of Recovery Works shall practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations. In all cases when a violation of Recovery Works policy or federal or state law is observed by a Recovery Works staff member, this policy shall be applicable.

REPORTING RESPONSIBILITY

Recovery Works policy requires staff members to report to the Ethics Officer instances of staff member violations of Recovery Works rules and procedures or of state or federal laws or regulations so that any situation can be rectified and any staff member involved can be corrected. If necessary, major violations may be reported to Recovery Works or relevant government agencies.

NO RETALIATION

Recovery Works policies encourage and enable staff members and others to raise serious concerns within the organization prior to seeking outside resolution. However, regardless of how and to whom the matter is reported, no director, officer or staff member who in good faith reports such policy, procedural or regulatory violations shall suffer harassment, retaliation or adverse employment consequences.

REPORTING VIOLATIONS

Ethics code violations, policy and procedural violations and violations of local, state or federal regulations should be reported to the Ethics Officer so that the reported matter can be investigated and corrected, as needed. Recovery Works staff members are also encouraged to raise questions, concerns, suggestions or complaints with their supervisor. In cases where a Recovery Works staff member is not comfortable speaking with the Ethics Officer or his or her supervisor or when the staff member is not satisfied with a response, the staff member is encouraged to communicate with the Communications Secretary or the Recovery Works Board of Directors. If the staff member feels it necessary, he or she may also send a report outside the center to an appropriate regulatory or governmental agency. Recovery Works staff may also report any violation of federal regulation 42 C.F.R. Part 2, such as a disclosure of student health information, directly to the United States Attorney for the judicial district in which the violation occurs.

COMPLIANCE

The Director of Administration is responsible for investigating and resolving reported complaints and allegations concerning Recovery Works ethics code violations. The Board of Directors has delegated overall responsibility for compliance to the Director of Legal Affairs. In the event a complaint is filed regarding alleged misrepresentation, mistreatment, discrimination or abuse, the matter will be investigated under the direct supervision of the Recovery Works Board Of Directors by the Director of Legal Affairs.

ACCOUNTING AND AUDITING MATTERS

The Board of Directors, via the Director of Legal Affairs, shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing of financial matters.

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.

CONFIDENTIALITY

Violations or suspected violations may be submitted anonymously or on a confidential basis by the complainant. Reports of violations or suspected violations shall be kept confidential, to the extent possible, consistent with the need to conduct an investigation.

HANDLING OF REPORTED VIOLATIONS

The Director of Administration shall notify the sender and acknowledge receipt of the reported violation or suspected violation within seven (7) business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. Any complaint will be resolved promptly. While most complaints will be resolved within seven (7) days, some may not be able to be resolved within that time and will be resolved as rapidly as is reasonably possible. If the individual feels that there is unnecessary delay in a resolution, he or she has the right to write a report to the Recovery Works Board of Directors stating the complaint and any problems regarding its resolution. Violations of a serious nature, including allegations of misrepresentation, mistreatment, discrimination or abuse, will be investigated under the direct supervision of the Recovery Works Board of Directors by the Director of Legal Affairs.