Direct Relief requires its directors, officers, employees and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. All employees and representatives of Direct Relief are to practice honesty and integrity in fulfilling their responsibilities and to comply with all applicable laws and regulations.
By this policy, Direct Relief provides a clear process through which directors, officers, employees and volunteers may address concerns, complaints or allegations that Direct Relief personnel are not complying with applicable laws, regulations or policies. The policy also provides for immediate investigation of credible concerns and resolution appropriate to the result of the investigation.
Matters involving an individual’s terms and conditions of employment, professional conduct, the policy against harassment and discrimination, or other such employment-related matters also may be addressed through the employee complaint procedures or directed to the HR Director immediately.
It is the responsibility of all directors, officers, employees and volunteers to comply with Direct Relief’s policies and procedures and to report violations or suspected violations or suspected fraudulent or dishonest conduct in accordance with this Whistleblower Policy.
Illustrative Types of Concerns
The following is a non-exhaustive list of reportable improprieties:
- Supplying false or misleading information on Direct Relief’s financial or other public documents, including its Form 990;
Questionable accounting or audit practices or matters;
- Providing false information to or withholding material information from Direct Relief’s Board of Directors or auditors;
- Destroying, altering, mutilating, concealing, covering up, falsifying, or making false entry in any records or computer files;
- Altering, destroying, or concealing a document, or attempting to do so, with the intent to impair the document’s availability for use in an official proceeding or otherwise obstructing, influencing, or impeding any official proceeding, in violation of federal or state law or regulations;
- Embezzling, self-dealing, private inurement (i.e., earnings of Direct Relief inuring to the benefit of a director, officer, or senior management) and private benefit (i.e., assets of Direct Relief, including product inventory, being used for personal gain or benefit);
- Pursuing a benefit or advantage in violation of Direct Relief’s Conflicts of Interest Policy;
- Authorizing, paying or receiving compensation for services or goods that are not rendered or delivered;
- Violating Direct Relief’s Harassment-Free Workplace Policy or Equal Opportunity Policy;
- Harassing, discriminatory or retaliatory conduct based on a legally protected characteristic (such as race, color, religion, sex, sexual orientation, national origin, age, and physical or mental disability or impairment), such conduct to include, but not be limited to: using remarks or actions of a sexual nature that are not welcome and are likely to be viewed as personally offensive, including sexual flirtations; unwelcome physical or verbal advances; sexual propositions; verbal abuse of a sexual nature; the display of sexually suggestive objects, cartoons, or pictures; physical contact of a sexual or particularly personal nature; and using epithets, slurs, negative stereotyping, and threatening, intimidating, or hostile acts that relate to a legally protected characteristic
- Facilitating or concealing any of the above or similar actions.
No Retaliation/Prompt Investigation
No director, officer, employee or volunteer who in good faith (as described below) reports a violation of Direct Relief’s policies and procedures shall suffer harassment, retaliation, or adverse employment consequence because of such a report. Reports of retaliation will be investigated promptly in a manner intended to protect confidentiality as much as practicable, consistent with a full and fair investigation. Consistent with state and federal law, employees making certain complaints will be advised of the outcome of the complaint. An employee who retaliates against a person who has reported a violation in accordance with this Whistleblower Policy is subject to disciplinary action up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within Direct Relief prior to seeking resolution outside Direct Relief.
Direct Relief has an open-door policy and allows employees to share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor may be in the best position to address an area of concern. However, if an employee is not comfortable speaking with the supervisor or is dissatisfied with the supervisor’s response, the employee is encouraged to speak with the HR Director or anyone in management who the employee is comfortable approaching. If an employee is not satisfied or comfortable with Direct Relief’s open-door policy, the employee should contact the Ethics and Compliance Hotline directly. Information on the Ethics and Compliance Hotline is set forth below.
Direct Relief’s supervisors and managers are required to report suspected violations of Direct Relief’s policies to the HR Director or an Executive Officer.
Notwithstanding the foregoing, all persons, including any director, officer, employee or volunteer of Direct Relief, may always communicate suspected violations, fraudulent acts, dishonest conduct or alleged retaliation through the Ethics and Compliance Hotline.
Violations or suspected violations may be submitted on a confidential basis by the reporting individual or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent necessary, consistent with the need to conduct a complete and fair investigation, for review of Direct Relief’s operations by its Board of Directors, its Audit Committee, the independent public accountants, and its legal counsel. If the reporting individual wishes to remain anonymous, it is not necessary that he or she provide a name or position in any such communication. However, even if reported anonymously, for a proper investigation to be conducted, the reporting individual must provide as much information as possible, sufficient to conduct a proper investigation, including where and when the incident occurred, names and titles of the individuals involved, and as much other detail as can be provided.
Ethics and Compliance Hotline
Concerns about violations of Direct Relief’s policies also may be reported through EthicsPoint, a third party ethics and compliance hotline. Direct Relief has set up EthicsPoint to support our culture of open communication and to foster a sense of integrity and trust. If you do not feel comfortable speaking to your supervisor or the HR Director or an Executive Officer, or if you would like to make an anonymous complaint, you may contact EthicsPoint, a third party resource. You should provide as much detail as possible, so that Direct Relief can conduct a meaningful investigation. All complaints or concerns received on the hotline will be investigated, as appropriate, by the appropriate party, based on the type of complaint.
Ethics and Compliance Hotline: 1 (844) 573-4161
Ethics and Compliance Website: directrelief.ethicspoint.com
Accounting and Auditing Matters
The Audit Committee shall address all reported concerns or complaints regarding corporate accounting practices, internal controls, or auditing, and the Chair of the Audit Committee of Direct Relief’s Board of Directors can be contacted in the event that you feel a concern or complaint has not been adequately addressed or if you would like to make a report about suspected policy violations:
Audit Committee Chair, Direct Relief
6100 Wallace Becknell Drive, Santa Barbara, CA 93117
Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation of Direct Relief’s policies and procedures must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of Direct Relief’s policies and procedures. Individuals making any allegations which prove to have been made maliciously or knowingly to be false may be subject to disciplinary action by Direct Relief and/or legal claims brought by individual(s) maliciously or knowingly falsely accused of such conduct.