To encourage those who have serious concerns about LiveDifferent to raise them, without fear of retaliation or reprisal.
This policy applies to employees, Board members, volunteers and all those external to the organization who have an interest in its operations.
C. Policy Statement
LiveDifferent is committed to the highest ethical standards. We do this by conducting our business with maximum integrity and by achieving full compliance with all applicable laws, rules, and regulations. In line with this commitment, LiveDifferent provides an avenue for its employees, Board members, volunteers and other stakeholders to report any concerns they may have about the activities covered by this policy and to be assured that they will be protected from reprisal or victimization for reporting their concerns in good faith.
This policy covers instances where an employee, Board member or other stakeholder has evidence of activity by any LiveDifferent employee, Board member or consultant (including external auditors) that to his/her knowledge constitutes a Reportable Activity, including:
– Accounting, auditing, or other financial reporting fraud or misrepresentation;
– Violations of federal or provincial laws or laws within the countries in which LiveDifferent operates that could result in fines or civil damages payable by LiveDifferent or that could otherwise significantly harm LiveDifferent’s reputation or public image;
– Unethical business conduct in violation of any LiveDifferent policy, including, but not limited to its Codes of Conduct;
– Danger to the health, safety, or well-being of employees, Board members and/or the general public;
– Harassment and bullying and discrimination.
LiveDifferent will not permit any employees, Board members, volunteers, consultants or external stakeholders to harass, retaliate or discriminate against any other employee, Board member, volunteer or stakeholder who, in good faith, has filed a Complaint. Retaliation in any form will not be tolerated. Harassment, retaliation, or discrimination, stemming from having reported a Reportable Activity is, itself, a Reportable Activity.
Any violation of this Policy may subject the violator to disciplinary action, which may include, in appropriate circumstances, termination of employment with cause or legal action.
Making a complaint not in good faith will be viewed as a serious offence, and may be subject to discipline up to and including termination of employment with cause, and/or the severing of the relationship with a Board member, supplier, or other stakeholder.
D. Procedure for Filing a Complaint
To file a complaint, please see Appendix A below for the Complaint Report Form. Once you have completed the form, send it to the COO, who has the responsibility for investigating such complaints and taking the appropriate action. In situations where the complaint is being filed against a Board Member or the CEO, the complaint can be sent to the Chair of the Board. Complaints against the Chair of the Board or the COO are to be sent to the CEO.
A Complainant may remain anonymous. However, in order to allow for a better investigation of a complaint, the Complainant should consider providing his/her name and contact information. Whether or not a name and contact information is provided, the substance of the complaint will be treated with utmost confidence and not discussed with others except to the minimum extent necessary to conduct a complete and fair investigation. In all cases, any person who is alleged to have conducted the Reportable Activity will be made aware of the complaint at an appropriate point during the investigation.
The Complainant should give enough information to enable a full investigation, including where and when the Reportable Activity occurred, names and titles of individuals involved, and as much other relevant detail as the Complainant can provide.
E. Investigation and Resolution of Complaint
The recipient of a complaint (either the COO, CEO or Board Chair) made in accordance with this policy (the “Investigator”) shall be responsible for expeditiously conducting or causing to be conducted an investigation of the complaint, resolving the matter, and reporting such resolution to the Complainant, where possible. Under no circumstances will the Investigator allow such investigation or resolution or reporting to be delegated to or shared by anyone whom the Complainant identified as being or having been involved in the Reportable Activity, or to whom the Investigator deems inappropriate.
In the event that the Complainant feels that the process was compromised or the resolution was not based on fair process or evidence, the Complaint may be escalated, only once, to the CEO or Board Chair. At that point, the resulting decision is to be considered final.