Pathway to Work requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of Pathway to Work, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

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

It is contrary to the values of Pathway to Work for anyone to retaliate against any board member, officer, employee or volunteer 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 Pathway to Work. 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.

Pathway to Work 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 the President, Board of Directors. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to Pathway to Work’s President, Board of Directors, who has the responsibility to investigate all reported complaints. 

Pathway to Work’s President, Board of Directors shall immediately notify the Board of Directors, including the Board Treasurer, of any concerns or complaints regarding corporate accounting practices, internal controls or auditing and work with the Board of Directors until the matter is resolved.

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.

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.

Pathway to Work’s President, Board of Directors 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.

                                                          Compliance Officer

Pathway to Work’s President, Board of Directors is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. They will advise the Board of Directors of all complaints and their resolution and will report at the conclusion of an investigation to the Board Treasurer on compliance activity relating to any accounting or alleged financial improprieties.