8.4 Whistleblower Policy

Background

The Sarbanes-Oxley Act of 2002, Section 1107, Retaliation against Informants, applies to all companies, public or private. It states that it is illegal to retaliate against a "whistleblower". It is in an organization's best interest to have a policy that provides clear procedures for handling whistleblower complaints. Proper handling of such complaints will help protect organizations from being accused of retaliation against whistleblowers. Such a policy, to be effective, must be circulated to all employees and Board members. It is recommended the Board review and adopt a Whistleblower Policy.

"We must practice honesty and integrity in fulfilling our responsibilities."

General

REACS's Code of Ethics and Conduct ("Code") requires Trustees, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of REACS, 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 Trustees, officers and employees to comply with the Code and to report violations or suspected violations in accordance with this Whistleblower Policy.

No Retaliation

No director, officer or employee who in good faith reports a violation of the Code 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 REACS prior to seeking resolution outside the agency.

Reporting Violations

The Code addresses REACS's open door policy and 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 you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor's response, you are encouraged to speak with anyone in management whom you are comfortable in approaching. Supervisors and managers are required to report suspected violations of the Code of Conduct to REACS's Compliance Officer, who has specific and exclusive responsibility to investigate all reported violations. For suspected fraud, or when you are not satisfied or uncomfortable with following REACS's open door policy, individuals should contact REACS's Compliance Officer directly. In the event of a complaint against the Compliance Officer, you may bring the matter to the Board Chair.

Compliance Officer

REACS's Compliance Officer is responsible for investigating and resolving all reported complaints and allegations concerning violations of the Code and, at his discretion, shall advise the Principal and/or the Executive Committee. The Compliance Officer has direct access to the Executive Committee of the Board of Trustees and is required to report to the Executive Committee at least annually on compliance activity. REACS's Compliance Officer is the Chene Williams, Vice President of the School Board, c.williams@reacschool.com
The Board Chair can be reached at 718-978-3707