UNITED ARTS COUNCIL OF RALEIGH & WAKE COUNTY, INC.
CODE OF ETHICS AND WHISTLEBLOWER PROTECTION POLICY
Adopted June 24, 2008
I.
CODE OF ETHICS AND CONDUCT
The Board of Directors (“Board”) of United Arts Council of Raleigh & Wake County,
Inc. (“UAC”) shall require all directors, officers, and employees (i) to observe high standards of
business and personal ethics in the conduct of their duties and responsibilities; (ii) to practice
honesty and integrity in fulfilling their responsibilities; and (iii) to comply with all UAC policies
and applicable laws and regulations (the “Code”).
II.
REPORTING RESPONSIBILITY
It is the responsibility of all directors, officers, and employees to comply with the Code
and to report violations or suspected violations in accordance with this policy.
III.
NO RETALIATION
No director, officer, or employee who in good faith reports a violation of the Code shall
suffer harassment, retaliation, or adverse employment consequence. 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 policy is intended to encourage and enable
employees and others to raise serious concerns within UAC prior to seeking resolution outside
UAC. Any complaint of retaliation shall be made immediately to the Compliance Officer who
shall promptly investigate such complaint.
IV.
REPORTING VIOLATIONS
The Board desires for directors, officers, and employees to share their questions,
concerns, suggestions, or complaints with someone who can address them properly. In most
cases, an employee’s supervisor is in the best position to address an area of concern. However, if
an employee is not comfortable speaking with his or her supervisor or the employee is not
satisfied with his or her supervisor’s response, the employee is encouraged to speak with the
President or with the Chair of the Board. Supervisors, the President, and the Chair of the Board
are required to report suspected violations of the Code to the Compliance Officer, who has
specific and exclusive responsibility to investigate all reported violations. For suspected fraud,
or when an employee is not satisfied or an employee is uncomfortable reporting an incident in
accordance with the above procedure, individuals should contact the Compliance Officer
directly.
It is preferable that reports be made in writing so as to assure a clear understanding of the
issues raised, but they may be made orally. Reports should be factual and should contain as
much specific information as possible to help determine proper assessment of the nature, extent,
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and urgency of preliminary investigative procedures. An oral report should be documented by a
written transcript and reviewed for accuracy by the complainant.
V.
COMPLIANCE OFFICER
UAC’s Compliance Officer is responsible for investigating and resolving all reported
complaints and all allegations concerning violations of the Code and, at his or her discretion,
shall advise the President and/or the Administration Committee of the Board of Directors. The
Compliance Officer has direct access to the Administration Committee and is required to report
to the Administration Committee at least annually on compliance activity. UAC’s Compliance
Officer is the Chair of the Administration Committee.
VI.
ACCOUNTING AND AUDITING MATTERS
The Finance Committee shall address all reported concerns or complaints regarding
corporate accounting practices, internal controls, or auditing. The Compliance Officer shall
immediately notify the Finance Committee of any such complaint and work with the Finance
Committee until the matter is resolved. Such complaints shall be retained as part of the
confidential records of the Finance Committee for a period of no less than five (5) years.
VII.
ACTING IN GOOD FAITH
Anyone filing a complaint concerning a violation or suspected violation of the Code must
be acting in good faith and have reasonable grounds for believing the information disclosed
indicates a violation of the Code. Any allegations that prove not to be substantiated and that
prove to have been made maliciously, knowingly to be false, or with reckless disregard of their
truth or falsity will be viewed as a serious disciplinary offense, including, but not limited to,
termination of employment. A false report may subject a complainant to liability for damages.
VIII. NO PUBLICITY
A complainant shall avoid any form of external or internal publicity concerning any
(suspected) breach or irregularity that he or she may want to report or has reported unless the
Compliance Officer has refused to investigate the matter and all alternatives for internal
consultation have been exhausted.
IX.
CONFIDENTIALITY
Violations or suspected violations 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, unless the complainant unilaterally, by his or her action, discloses the nature of the
report.
X.
HANDLING OF REPORTED VIOLATIONS
The Compliance Officer will notify the complainant, if known, and acknowledge receipt
of the reported violation or suspected violation within five (5) business days. All reports will be
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promptly investigated, and appropriate corrective action will be taken if warranted by the
investigation. After the investigation has been completed, the complainant shall be advised of
the results of the investigation, except personnel actions taken as a result of the investigation
shall be kept confidential.
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