Whistleblower Policy and Procedures
Purpose
Every director, officer or employee of the Cattaraugus County Land Bank Corporation, and every member of the Board of Directors of the Cattaraugus County Land Bank Corporation, in the performance of their duties shall conduct themselves with honesty and integrity and observe the highest standards of business and personal ethics as set forth in the Cattaraugus County Land Bank Corporation Code of Ethics.
Policy
It is the policy of Cattaraugus County Land Bank Corporation to afford certain protections to individuals who in good faith report violations of the Cattaraugus County Land Bank Corporation’s Code of Ethics or other instances of potential wrongdoing within the Cattaraugus County Land Bank Corporation. The Whistleblower Policy and Procedures set forth below are intended to encourage and enable employees to raise concerns in good faith within the Cattaraugus County Land Bank Corporation and without fear of retaliation or adverse employment action.
Definitions
“Good Faith”: Information concerning potential wrongdoing is disclosed in “good faith” when the individual making the disclosure reasonably believes such information to be true and reasonably believes that it constitutes potential wrongdoing.
“Cattaraugus County Land Bank Corporation Employee”: All board members, and officers and staff employed at this Public Cattaraugus County Land Bank Corporation whether full-time, part-time, employed pursuant to contract, employees on probation and temporary employees.
“Whistleblower”: Any Public Cattaraugus County Land Bank Corporation Employee (as defined herein) who in good faith discloses information concerning wrongdoing by another Public Cattaraugus County Land Bank Corporation employee, or concerning the business of the Public Cattaraugus County Land Bank Corporation itself.
“Wrongdoing”: Any alleged corruption, fraud, criminal or unethical activity, misconduct, waste, conflict of interest, intentional reporting of false or misleading information, or abuse of Cattaraugus County Land Bank Corporation engaged in by a Public Cattaraugus County Land Bank Corporation Employee (as defined herein) that relates to the Public Cattaraugus County Land Bank Corporation.
“Personnel action”: Any action affecting compensation, appointment, promotion, transfer, assignment, reassignment, reinstatement or evaluation of performance.
Section I: Reporting Wrongdoing
All Cattaraugus County Land Bank Corporation Employees who discover or have knowledge of potential wrongdoing concerning board members, officers, or employees of the Cattaraugus County Land Bank Corporation; or a person having business dealings with Cattaraugus County Land Bank Corporation; or
concerning the Cattaraugus County Land Bank Corporation itself, shall report such activity in accordance with the following procedures:
a) The Cattaraugus County Land Bank Corporation Employee shall disclose any information concerning wrongdoing either orally or in a written report to his or her supervisor, or to the Cattaraugus County Land Bank Corporation’s ethics officer, general counsel or human resources representative.
b) All Cattaraugus County Land Bank Corporation Employees who discover or have knowledge of wrongdoing shall report such wrongdoing in a prompt and timely manner.
c) The identity of the whistleblower and the substance of his or her allegations will be kept confidential to the best extent possible.
d) The individual to whom the potential wrongdoing is reported shall investigate and handle the claim in a timely and reasonable manner, which may include referring such information to the Authorities Budget Office or an appropriate law enforcement agency where applicable.
e) Should a Cattaraugus County Land Bank Corporation Employee believe in good faith that disclosing information within the Cattaraugus County Land Bank Corporation pursuant to Section 1(a) above would likely subject him or her to adverse personnel action or be wholly ineffective, the Cattaraugus County Land Bank Corporation Employee may instead disclose the information to the Authorities Budget Office or an appropriate law enforcement agency, if applicable. The Authorities Budget Office’s toll free number (1-800-560-1770) should be used in such circumstances.
Section II: No Retaliation or Interference
No Cattaraugus County Land Bank Corporation Employee shall retaliate against any whistleblower for the disclosure of potential wrongdoing, whether through threat, coercion, or abuse of Cattaraugus County Land Bank Corporation; and, no Cattaraugus County Land Bank Corporation Employee shall interfere with the right of any other Cattaraugus County Land Bank Corporation Employee by any improper means aimed at deterring disclosure of potential wrongdoing. Any attempts at retaliation or interference are strictly prohibited and:
a) No Cattaraugus County Land Bank Corporation Employee who in good faith discloses potential violations of this Cattaraugus County Land Bank Corporation’s Code of Ethics or other instances of potential wrongdoing, shall suffer harassment, retaliation or adverse personnel action.
b) All allegations of retaliation against a Whistleblower or interference with an individual seeking to disclose potential wrongdoing will be thoroughly investigated by Cattaraugus County Land Bank Corporation.
c) Any Cattaraugus County Land Bank Corporation Employee who retaliates against or had attempted to interfere with any individual for having in good faith disclosed potential violations of Cattaraugus County Land Bank Corporation’s Code of Ethics or other instances of potential wrongdoing is subject to discipline, which may include termination of employment.
d) Any allegation of retaliation or interference will be taken and treated seriously and irrespective of the outcome of the initial complaint, will be treated as a separate matter.
Date Adopted: 10/12/2016