whistleblower-policy-2015

Vellore Christian Medical College Foundation, Inc. Whistleblower Policy The Vellore Christian Medical College Foundation, Inc. (“Foundation”) is committed to lawful and ethical behavior in all its activities and requires that its Board of Directors, employees, Corporate members, and consultants observe high ethical standards in fulfilling their responsibilities. Set forth below is the policy of Foundation with respect to reporting concerns about the legality or propriety of activities of directors, employees, consultants, and members of Foundation.

Reporting concerns: It is the responsibility and expectation of all directors, employees, consultants, and members of Foundation to report suspected wrongdoing that is in violation of commonly held ethical standards, rules of charitable organizations, or public laws. Anyone who suspects a violation should promptly report to the Foundation’s President in writing. If this officer is unresponsive, the individual should report his or her concern to the Chair of the Board of Directors.

Investigation: The Foundation’s President and/or Chair of the Board of Directors will act on all reports with care and in a timely manner. The officers will act as discretely as possible, maintaining confidentiality as much as is possible within the confines of a small organization.

Reports may be made anonymously, understanding that in a small organization, anonymity may be impossible to maintain.

No Retaliation: The Foundation and its officers will not discharge, threaten or discriminate in any manner against an individual for his/her good faith reporting what he/she perceives to be wrongdoing. The Foundation may initiate a disciplinary measure against anyone who threatens or retaliates against an individual who makes a good faith report of suspected wrongdoing.

Types of concerns that should be reported: Following are examples of the kinds of actions that should be reported: Knowingly supplying false or misleading information on financial reports or other financial or property documents; Providing false information to or withholding material information from the auditors of Foundation; Embezzlement, self-dealing, private inurement and private benefit (i.e. Foundation revenue or assets being used for personal gain); Violations of Foundation fiscal or investment policies; Violations of public criminal codes; Payment for services or goods that are not delivered; Facilitating or concealing any of the above or similar actions.

Acting in Good Faith: Anyone making a report of suspected wrongdoing must be acting in good faith and have reasonable grounds for believing the information being reported is true and shows clear evidence of wrongdoing. Any allegations that prove to be unsubstantiated and that prove to have been made maliciously will be viewed as a serious offense which may result in disciplinary action.

Annual Statements: Each director, officer and employee of the Foundation shall annually sign a statement which affirms that such person: a. has received a copy of this Whistleblower Policy, b. has read and understands the policy, and c. has agreed to comply with the policy.

Electronic signature shall serve the same purpose as pen/ink signature.

Right to Amend/Supplement Reserved The Foundation reserves the right to amend and/or supplement this policy at any time.

Agreed and executed by:

_________________________________ Signed

_________________________ Date

_________________________________ Print Name

2 The Vellore Christian Medical College Foundation, Inc. Whistleblower Policy Adopted 30 April 2010