Whistleblower Policy.

Purpose:  The Lone Star Chapter of the National Hemophilia Foundation (LSC) and its affiliates  are committed to high standards of ethical, moral and legal business conduct.  For this reason, and LSC’s commitment to open communication, this policy provides an avenue for its Employees and Board of Directors to raise concerns and reassurance that they will be protected from reprisals or victimization for whistleblowing.

Policy Statement:  This whistleblowing policy is intended to cover protections for employees and Board members who may raise concerns regarding LSC or its affiliates, such as:

  • Incorrect financial reporting

  • unlawful activity

  • activities that are not in line with LSC’s policies

  • activities, which otherwise amount to serious improper conduct.

 The Lone Star Chapter of NHF follows provisions set forth in the Texas State Whistleblower Law.

Safeguards

 Harassment or Victimization – Harassment or victimization for reporting concerns under this policy will not be tolerated.

Confidentiality – Every effort will be made to treat the complainant’s identity with appropriate regard for confidentiality.

Anonymous Allegations – This policy encourages complainants to put their names to allegations because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified.

Concerns expressed anonymously will be explored appropriately, 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.

Bad Faith Allegations – Allegations in bad faith may result in disciplinary action.

 Procedure:

  1. Process for Raising a Concern

Reporting – The whistleblowing procedure is intended to be used for serious and sensitive issues.  Such concerns, including those relating to financial reporting, unethical or illegal conduct, may be reported directly to the President of the Board of Directors.  If the concern is about the President of the Board of Directors, it should be reported to the 1st Vice President of the Board of Directors.

Employment-related concerns - These should continue to be reported through your normal channels such as your supervisor, or to the President of the Board of Directors.

Timing – The earlier a concern is expressed, the easier it is to take action.

Evidence – Although the complainant is not expected to prove the truth of an allegation, the complainant should be able to demonstrate to the person contacted that the report is being made in good faith.

2. How the Report of Concern will be Handled

The action taken by LSC or its affiliates in response to a report of concern under this policy will depend on the nature of the concern.  The Executive Committee, or Officers, of the Board of Directors shall receive information on each report of concern and follow-up information on actions taken.

Initial Inquiries – Initial inquiries will be made to determine whether an investigation is appropriate, and the form that it should take.  Some concerns may be resolved without the need for investigation.

 Further Information – The amount of contact between the complainant and the person or persons investigating the concern will depend on the nature of the issue and the clarity of information provided.  Further information may be sought from or provided to the person reporting the concern. 

Protection from Retaliation

Lone Star Chapter of NHF and its affiliates, prohibits retaliation by or on behalf of LSC against staff or volunteers for making good faith complaints, reports or inquiries under this policy or for participating in a review or investigation under this policy.  This protection extends to those whose allegations are made in good faith but prove to be mistaken.  LSC and its affiliates, reserve the right to discipline persons who make bad faith, knowingly false, or vexatious complaints, reports, or inquiries or who otherwise abuse this policy.