Complaints, Whistleblower

PURPOSE

United for Literacy requires directors, 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 organization, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

This policy is intended to encourage and enable Board members, volunteers, learners, employees and other stakeholders to raise serious concerns so that United for Literacy can address and correct inappropriate conduct and actions. It is the responsibility of all Board members, employees and volunteers to report concerns about violations of United for Literacy’s governing policies or suspected violations of law or regulations that govern United for Literacy’s operations.

Anonymous complaints will not be entertained under this policy.

No Retaliation

It is contrary to the values of United for Literacy for anyone to retaliate against anyone who, in good faith, reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of the organization. Any employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

Scope

This policy applies to all United for Literacy directors, volunteers, learners, employees and other stakeholders.

APPLICATION

Employees are encouraged to share their concerns or complaints with their supervisor or by email to [email protected] . Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations to the VP, Finance. In the event that a complaint involves the VP, Finance directly, the report should be made to the President.

Volunteers are encouraged to share their concerns or complaints with an employee or by email to [email protected]. Employees are required to report complaints or concerns of which they are made aware by a volunteer to the VP, Finance.

Board Members are encouraged to share their concerns or complaints with the Chair of the Board (United for Literacy or United for Literacy Foundation).

Learners are encouraged to share their concerns or complaints with an employee or by email to [email protected]. Employees are required to report complaints or concerns of which they are made aware by a learner to the VP, Finance.

Stakeholders are encouraged to share their concerns or complaints by telephone (1-800-555-6523) or by email to [email protected].

Acting in Good Faith

Anyone filing a written 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 serious. In the case of employees, such offenses may be subject to discipline up to and including termination of employment.

Confidentiality

Violations or suspected violations may be submitted confidentially by the complainant. 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 complainant will be notified with an acknowledgment that the complaint was received. All reports of violations or suspected violations will be investigated and appropriate corrective action will be taken if warranted by the investigation.

Procedure

A complaint may fall into one of the following categories:

• Violation of an organizational policy
• Discrimination and/or harassment (as per ERF1 – Anti-violence, Anti-discrimination, Anti- harassment Policy)
• A serious difference of opinion as to the adherence, interpretation, or administration of policy concerns regarding corporate accounting practices, internal controls or auditing
• The belief that a serious problem cannot be resolved without a formal resolution

Step One

Complaints by Employees:

· Complainants are encouraged to bring any and all serious concerns to the attention of their supervisor either verbally or in writing

· The supervisor will provide advice and counsel and will encourage the complainant, wherever possible and reasonable, to talk to the person who has caused the concern

· If the matter can be resolved between the various parties with the advice and counsel of the supervisor, the process will end at Step One

· The supervisor is responsible for the following:

• Dealing with all complaints, concerns or disputes in a timely and efficient manner
• Documenting all conversations in terms of facts, dates and counsel given
• Following up with the complainant to ensure that a satisfactory resolution has been achieved

Complaints by Board Members:

· Complainants are encouraged to bring any and all serious concerns to the attention of the Chair of the Board either verbally or in writing

· The Chair of the Board will provide advice and counsel and will encourage the complainant, wherever possible and reasonable, to talk to the person who has caused the concern

· If the matter can be resolved between the various parties with the advice and counsel of the Chair of the Board, the process will end at Step One

· The Chair of the Board is responsible for the following:

• Dealing with all complaints, concerns or disputes in a timely and efficient manner
• Documenting all conversations in terms of facts, dates and counsel given
• Following up with the complainant to ensure that a satisfactory resolution has been achieved

Complaints by volunteers and learners:

· Complainants are encouraged to bring any and all serious concerns to a staff person

· A staff person will provide advice and counsel and will encourage the complainant, wherever possible and reasonable, to talk to the person who has caused the concern

· If the matter can be resolved between the various parties the process will end at Step One

· A designated investigator (either internal or external) will be responsible for the following:

• Dealing with all complaints, concerns or disputes in a timely and efficient manner
• Documenting all conversations in terms of facts, dates and counsel given
• Following up with the complainant to ensure that a satisfactory resolution has been achieved

Complaints by the general public:

· Complainants are encouraged to bring any and all serious complaints to [email protected] (or 1-800-555-6523)

· If the matter can be resolved between the various parties the process will end at Step One

· A designated investigator (either internal or external) will be responsible for the following:

• Dealing with all complaints, concerns or disputes in a timely and efficient manner
• Documenting all conversations in terms of facts, dates and counsel given
• Following up with the complainant to ensure that a satisfactory resolution has been achieved

Step Two

· If the complainant is not satisfied that Step One has resolved the matter they can, within ten business days of Step One proving unsatisfactory, complain in writing to the VP, Finance [email protected]) or to the Chair of the Board (ONLY regarding complaints brought by Directors) · The VP, Finance [email protected]) or Chair of the Board (ONLY regarding complaints brought by Directors) will investigate or arrange to have the complaint investigated

· An investigation may entail interviews, collecting documents or consulting with others or outside advisors or legal counsel in the course of resolving the dispute

· If the proposed resolution is satisfactory the complainant, the VP, Finance ([email protected]) or Chair of the Board (ONLY regarding complaints brought by Directors) will sign the written summary acknowledging that the resolution was satisfactory

APPEAL

[email protected]If the proposed resolution is not satisfactory to the complainant or cannot be executed, as it does not meet with agreement from the complainant, the VP, Finance ([email protected] ) the President, or Chair of the Board (ONLY regarding complaints brought by Directors) may engage outside counsel to conduct research and make recommendations to the President and/or the Chair of the Board.

· A written appeal must include all past reports and recommendations along with an explanation as to why Step Two did not prove satisfactory and a description of the resolution being sought

· An investigator may conduct interviews, collect documents or consult with outside advisors in the course of resolving the dispute

· Once the appeal is received, a resolution will be offered to the complainant within 30 days

· If the complainant and all attached parties are satisfied that the resolution is satisfactory, all parties will sign an agreement acknowledging such

· A decision made by the President or Chair of the Board through the appeal process is final

United for Literacy will take all reasonable steps to ensure that policies and procedures contribute to the overall health of the organization and are understood and consistently and fairly applied. At any point during the dispute resolution process the parties to the complaint may choose to utilize the resources of the applicable Human Rights Commission or Human Rights Tribunal or agencies such as Employment (Labour) Standards and/or Occupational Health and Safety. (United for Literacy will abide by legislation appropriate to each province/territory in which it operates.)

In the event that a complainant opts to engage an outside forum for resolution of the complaint, the procedure described in this policy may be suspended and/or terminated.

At any point, United for Literacy may engage outside counsel to conduct any of the steps outlined in this policy on its behalf.

Policy approved by the United for Literacy Board of Directors on January 27, 2023

CREATED AND APPROVED: September 2012 REVISED: February 2024