Every director, officer or employee of the Cattaraugus County Economic Sustainability and Growth Corporation, Inc. (“CCESGC”) and every member of the Board of Directors of CCESGC, in the performance of their duties shall conduct themselves with honesty and integrity and observe the highest standards of business and personal ethics as set forth in CCESGC’s Code of Ethics Policy.
It is the policy of the Cattaraugus County Economic Sustainability and Growth Corporation to afford certain protections to individuals who in good faith report violations of CCESGC’s Code of Ethics or other instances of potential wrongdoing within CCESGC. The Whistleblower Policy and Procedures set forth below are intended to encourage and enable employees to raise concerns in good faith within CCESGC and without fear of retaliation or adverse employment action.
- “Good Faith”: Information concerning potential wrongdoing is disclosed in “good faith” when the individual making the disclosure reasonably believes such information to be true and reasonably believes that it constitutes potential wrongdoing.
- “Cattaraugus County Economic Sustainability and Growth Corporation Employee”: All board members, and officers and staff employed at this Public Cattaraugus County Economic Sustainability and Growth Corporation whether full-time, part-time, employed pursuant to contract, employees on probation and temporary employees.
- “Whistleblower”: Any CCESGC Employee (as defined herein) who in good faith discloses information concerning wrongdoing by another CCESGC employee, or concerning the business of CCESGC itself.
- “Wrongdoing”: Any alleged corruption, fraud, criminal or unethical activity, misconduct, waste, conflict of interest, intentional reporting of false or misleading information, or abuse of CCESGC engaged in by a CCESGC Employee (as defined herein) that relates to CCESGC.
- “Personnel action”: Any action affecting compensation, appointment, promotion, transfer, assignment, reassignment, reinstatement or evaluation of performance.
Section I: Reporting Wrongdoing
All Cattaraugus County Economic Sustainability and Growth Corporation Employees who discover or have knowledge of potential wrongdoing concerning board members, officers, or employees of CCESGC; or a person having business dealings with CCESGC; or concerning CCESGC itself, shall report such activity in accordance with the following procedures:
- CCESGC Employee shall disclose any information concerning wrongdoing either orally or in a written report to his or her supervisor, or to CCESGC’s ethics officer, general counsel or human resources representative.
- All CCESGC Employees who discover or have knowledge of wrongdoing shall report such wrongdoing in a prompt and timely manner.
- The identity of the whistleblower and the substance of his or her allegations will be kept confidential to the best extent possible.
- The individual to whom the potential wrongdoing is reported shall investigate and handle the claim in a timely and reasonable manner, which may include referring such information to the Authorities Budget Office or an appropriate law enforcement agency where applicable.
- Should a CCESGC Employee believe in good faith that disclosing information within the Cattaraugus County Economic Sustainability and Growth Corporation pursuant to Section 1(a) above would likely subject him or her to adverse personnel action or be wholly ineffective, the CCESGC Employee may instead disclose the information to the Authorities Budget Office or an appropriate law enforcement agency, if applicable. The Authorities Budget Office’s toll free number (1-800-560-1770) should be used in such circumstances.
Section II: No Retaliation or Interference
No Cattaraugus County Economic Sustainability and Growth Corporation Employee shall retaliate against any whistleblower for the disclosure of potential wrongdoing, whether through threat, coercion, or abuse of CCESGC; and, no CCESGC Employee shall interfere with the right of any other CCESGC Employee by any improper means aimed at deterring disclosure of potential wrongdoing. Any attempts at retaliation or interference are strictly prohibited and:
- No CCESGC Employee who in good faith discloses potential violations of CCESGC’s Code of Ethics or other instances of potential wrongdoing, shall suffer harassment, retaliation or adverse personnel action.
- All allegations of retaliation against a Whistleblower or interference with an individual seeking to disclose potential wrongdoing will be thoroughly investigated by CCESGC.
- Any CCESGC Employee who retaliates against or had attempted to interfere with any individual for having in good faith disclosed potential violations of CCESGC’s Code of Ethics or other instances of potential wrongdoing is subject to discipline, which may include termination of employment.
- Any allegation of retaliation or interference will be taken and treated seriously and irrespective of the outcome of the initial complaint, will be treated as a separate matter.
Adopted: April 18, 2018