Raising Concerns Policy

Every Company Needs a Documented Policy for Raising Concerns

Sample Guidelines for Raising Concerns

  • Reports of possible violations will be forwarded to specific employee designee
  • The employee designee may, in their discretion, assume responsibility for evaluating any possible violation and directing or conducting any investigation, or may delegate any portion of such responsibility to the Board of Directors, another committee or another person or entity.
  • If the employee designee chooses to assume responsibility for evaluating any possibly violation or directing or conducting any investigation where the investigation concerns a possible violation by a member of the Board of Directors, the Audit committee, not including that member, shall assume such responsibility.
  • The employee designee shall have the authority to engage independent counsel and other advisors, as it deems necessary, to assist in its investigation and decision process.
  • After conducting the investigation, the results will be evaluated and the Company shall authorize such response, follow-up and preventative actions, if any, as are deemed necessary and appropriate to address the substance of the reported possible violation.

Sample Guidelines for Company Position

The Company will not penalize or retaliate against any person or entity for reporting a possible violation in good faith. The Company will not tolerate retaliation against any person or entity for submitting, or for cooperating in the investigation of, a possible violation. Any retaliation will warrant disciplinary action against the person who wrongfully retaliates, up to and including termination of employment

Sample Guidelines for Employees Raising Concerns

If any person has questions regarding the appropriate course of action in a particular situation, they may contact the Compliance Officer or the Company’s Legal Department.

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