Policy Statement – The Agency’s Confidentiality, Personal Conduct, and Ethics policies require the Board of Directors, Senior Management, supervisors, and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the Agency, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations and code of ethics.
Reporting Responsibility – It is the responsibility of all members of the Board of Directors, and all employees, to comply with these policies, and to report violations or suspected violations of the law in accordance with this Whistleblower policy.
No Retaliation – An employee who reasonably believes that some policy, practice, or activity of the Agency is in violation of law or is an ethics violation, and reports such activity in good faith, shall not suffer harassment, retaliation or adverse employment consequence of any kind. 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. This Whistleblower policy is intended to encourage and enable employees and others to raise serious concerns within the Agency prior to seeking resolution outside the Agency.
Reporting Violations – ACAP has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor is the best individual for this purpose. However, if an employee is not comfortable speaking with their supervisor or is not satisfied with the supervisor’s response, the employee is encouraged to speak with anyone in Senior Management, including the CEO, whom the employee feels comfortable approaching. The CEO has specific and exclusive responsibility to investigate all reported violations. For suspected fraud, or when not satisfied or uncomfortable with following the Agency’s open door policy, or if the complaint concerns the CEO, individuals should contact the President of the Board of Directors. ACAP will investigate anonymous complaints of illegal, dishonest, or fraudulent activity if reported to the CEO or President of the Board of Directors.
Accounting and Auditing Matters – The Audit Committee shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The CEO shall immediately notify the Audit Committee of any such complaint and work with the Audit Committee until the matter is resolved.
Acting in Good Faith – Anyone filing a 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 of law may be submitted on a confidential basis by the complainant or may be submitted anonymously. 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 – As the Compliance Officer, the CEO is responsible for investigating and resolving all reported complaints and allegations concerning violations of law or ethics violations. The CEO will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days. If the complaint concerns the CEO, the President of the Board of Directors will notify the sender and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate disciplinary action will be taken if warranted by the investigation.