(Including Waste and Inappropriate Use of Assets)
Q: Why is a policy on fraud and wrongdoing necessary? Has there been fraud at EngenderHealth?
A: A policy on the reporting of fraud and wrongdoing (which includes waste and inappropriate use of assets) has been under development at EngenderHealth for more than a year. The decision to develop such a policy was based on the need for the organization to exercise due diligence and ensure that EngenderHealth has a policy in place to address the identification of, reporting of, and steps for preventing and avoiding fraud and wrongdoing.
While there have been instances of fraudulent acts by employees, these acts were caught because of our standard operating procedures (SOPs), field audits, informants, etc. The Fraud and Wrongdoing Policy is another step that will help us prevent such acts from happening in the future.
Q: Does the Fraud and Wrongdoing Policy cover only theft by an employee?
A: No. The policy covers any inappropriate acts by EngenderHealth employees, seconded employees, temporary employees, or casual staff and consultants. It does not deal only with cases of theft; it would also apply to any of the following:
Q: What does EngenderHealth consider fraud? How is it defined?
A: Fraud generally involves a willful or deliberate act in which a person tries to obtain an unauthorized benefit, such as money or property, by deception or other unethical means.
Q: What should I do if I suspect that someone is committing some kind of wrongdoing?
A: Your first step in such a case should be to discuss the situation with your supervisor. If you believe that your supervisor is involved in the situation, or if you are not comfortable discussing the problem with your supervisor, we strongly suggest that you report the situation anonymously, using either the EthicsPoint web site or the toll-free hotline number.
Q: Can I be fired by my supervisor for reporting wrongdoing?
A: No disciplinary action will be taken against anyone who reports suspected fraudulent activity or other wrongdoing in good faith.
Q: Can employees based overseas place a telephone call to report fraud or wrongdoing?
A: Staff based in the United States and Canada can call 866-739-4117 (toll-free) to make an anonymous report of suspected wrongdoing. However, that number does not work for other countries. Employees outside of the United States or Canada should call the number for your country on the International Toll-Free Dialing Instructions, or can make a report using the EthicsPoint web site.
Q: Can I be fired by my supervisor for reporting misconduct?
A: No disciplinary action will be taken against anyone who reports suspected fraudulent activity in good faith.
Q: What if I report misconduct to my supervisor and s/he does nothing about it?
A: You should then take the matter to one of the following:
Q: If I suspect wrongdoing, should I investigate it myself first to be sure before reporting it?
A: No. If you have reason to believe that a fraudulent act or any other wrongdoing occurred, you should report it immediately, so it can be investigated by the appropriate EngenderHealth staff.
Q: What protection is there for me if I report wrongdoing of some kind?
A: EngenderHealth will make every effort possible to protect the identity of any individual who reports any sort of wrongdoing. EngenderHealth will also undertake all measures necessary to ensure that no retaliation against the “whistleblower” occurs.
Q: What happens if I suspect wrongdoing, I report it, and I turn out to have been mistaken? Will I be disciplined?
A: No disciplinary action will be taken against anyone reporting wrongdoing, so long as the report was made in good faith. However, a report made maliciously or with knowledge that it was false may result in disciplinary action.
Q: Are managers the only staff who are authorized to report fraud or wrongdoing?
A: No. All staff members have that responsibility.
Q: If a vendor takes me out to lunch or gives me a holiday present, can I be accused of fraud or wrongdoing for not reporting it?
A: Accepting gifts from vendors does not constitute wrongdoing as long as it is done with good business ethics and does not obligate you for future benefits from the vendor or have any impact on your decision making. In this regard, employees’ behavior should always be in line with EngenderHealth’s Gift Acceptance Policy. This policy is available on the EngenderHealth Intranet.
Q: Who is responsible for preventing fraud and wrongdoing?
A: All levels of management and staff are responsible for the detection and prevention of fraud and wrongdoing.
Q: Is anyone in the organization exempt from being investigated for wrongdoing?
A: All allegations of fraud against anyone at EngenderHealth are investigated.
Q: What happens if someone maliciously accuses me of wrongdoing?
A: In such a case, the person would be subject to disciplinary action.
Q: What happens when an allegation of wrongdoing is investigated?
A: In an investigation of wrongdoing, the investigation team gathers all relevant information and issues a report to the President; the President then reports the allegation and the findings of the investigation team to the Board of Directors. These steps are followed in each case, regardless of whether the investigation substantiates that fraudulent activities occurred.
Q: Who determines if an investigation of wrongdoing should be conducted?
A: The President of EngenderHealth does.
Q: Are donors informed about an investigation of fraud or wrongdoing?
A: A donor is informed of such an investigation if its funds are involved.
Q: Is it mandatory that I sign the “Employee Acknowledgment Form” for fraud and wrongdoing?
A: Yes.
Q: How do I access EngenderHealth Human Resource policies and SOPS?
A: EngenderHealth Policies and SOPS are found on our Intranet
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Do not use this site to report events presenting an immediate threat to life or property. Reports submitted through this service may not receive an immediate response. If you require emergency assistance, please contact your local authorities.