MCL Whistleblower Policy

Mass Care Link, Inc. (MCL) requires directors, managers, and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of MCL, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that MCL can address and correct inappropriate conduct and actions. It is the responsibility of all board members, managers, employees, and volunteers to report concerns about violations of MCL’s code of ethics or suspected violations of law or regulations that govern MCL’s operations.

No Retaliation

It is contrary to the values of MCL for anyone to retaliate against any board member, manager, employee, or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, suspected fraud, or suspected violation of any regulation governing the operations of MCL.

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.

Reporting Procedure

MCL has an open-door policy and suggests that employees share their questions, concerns, suggestions, or complaints with their supervisor. 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 Tara Araujo, Chief Executive Officer.

Supervisors and managers are required to report their own or received complaints or concerns about suspected ethical and legal violations in writing to MCL’s CEO, who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may submit their concerns in writing directly to their supervisor, the chief executive officer or the organization’s general counsel.

The chief executive officer is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The CEO will advise the general counsel of all complaints and their resolution. 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 a serious disciplinary offense. Confidentiality violations or suspected violations may be submitted on a confidential basis 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 CEO will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation.

MCL’s Whistleblower’s Policy will be made available in the Employee Manual; copy always present in the lounge area of the office and MCL.

Confidentiality

Protected disclosures may be submitted on a confidential basis and/or anonymously by the individual submitting a report. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Audit Committee

At the discretion of the chief executive officer, in appropriate circumstances, a complaint/report may be assigned to the audit committee who will be responsible for investigating and resolving all reported complaints and allegations concerning protected disclosures and all findings/results will be reported to the chief executive officer.

The audit committee shall address all reported concerns or complaints regarding MCL’s violation of state or federal law, corporate accounting practices, internal financial controls, or auditing. The audit committee chair shall immediately notify the audit committee of any such complaint and work with the committee until the matter is resolved.

Handling of Reported Violations

The audit committee chair will promptly notify the sender and acknowledge receipt of a Protected Disclosure (unless such report was submitted anonymously). All reports will be investigated promptly, and appropriate corrective action will be taken if warranted by the investigation. Reports and copies of Protected Disclosures shall be retained by MCL’s legal counsel.