The Organization for Tropical Studies, Inc. (“OTS”) requires that its directors, officers, employees and volunteers (a) observe high standards of business and personal ethics in the conduct of their duties and responsibilities and (b) comply with every law, rule and regulation in all countries in which OTS operates and comply with all OTS policies.
All employees and volunteers are encouraged to report any concerns or complaints regarding illegal practices or violations of adopted OTS policies so that OTS can address and correct any inappropriate conduct or actions. It is the responsibility of all directors, officers, employees and volunteers to report concerns about ethical misconduct or suspected violations of laws or of OTS policies. The OTS Board of Directors will oversee this Policy.
No employee or volunteer who in good faith reports a violation or cooperates in the investigation of a violation shall suffer harassment, retaliation or adverse employment or volunteer consequences. It is contrary to the values of OTS for anyone to retaliate against any director, officer, employee or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, suspected fraud, or suspected violation of any policy or regulation governing OTS. Any employee or volunteer who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of OTS employment or termination of volunteer status with OTS.
OTS suggests that employees share their concerns or complaints with their supervisor. If an employee is not comfortable speaking with the employee’s supervisor or is not satisfied with the supervisor’s response, employees are encouraged to speak with the OTS President and CEO, or with the Chair of the Board or another OTS board member. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the President and CEO, who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or to the Chair of the Board of Directors. Volunteers may share their concerns or complaints with any person within OTS who may be properly able to address them. The President and CEO of OTS is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The President and CEO shall be the designated “Compliance Officer” and will advise the Board of Directors of all complaints and their resolution and will report at least annually to the Audit Committee on compliance activity relating to accounting or alleged financial improprieties. 2 In the event the reporting person believes the President and CEO may have committed a violation of this Policy, then the suspected violation should be reported directly to the Chair of the Board of Directors or to any other member of the Board of Directors.
ACCOUNTING AND AUDITING MATTERS
The President and CEO as the Compliance Officer shall immediately notify the Audit Committee and the Chair of the Board of any concerns or complaints or reports regarding possible violations of this Policy involving corporate accounting practices, internal controls or auditing or the material theft or diversion or embezzlement of assets and shall work with the Audit Committee until the matter is resolved.
ACTING IN GOOD FAITH
Anyone filing a written complaint under this Policy concerning a violation or suspected violation must be acting in good faith and must have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that cannot be substantiated and are not reasonably based on available information and which prove to have been made maliciously or which are known to be false will be viewed as a serious disciplinary offense.
In conducting its investigations and in reporting complaints, OTS will strive to keep as confidential the identity of any complainant or the identity of any individual who provides information during an investigation, except that the Organization may share such information as it deems necessary with appropriate OTS personnel and advisors to OTS, or as may be required by law or as may be necessary to conduct an adequate investigation, to cooperate with law enforcement authorities, or to provide for the safety of OTS employees or volunteers or the public.
HANDLING OF REPORTED VIOLATIONS
The Organization will acknowledge its receipt of any complaint of any reported or suspected violation of this Policy if the complainant’s identity and address is provided. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.
ACTION ON COMPLAINTS
OTS will take appropriate action in response to any complaints, including disciplinary action against any person who, in the Organization’s assessment, has engaged in unethical conduct or misconduct and, where appropriate, will report such misconduct to the relevant civil or criminal authorities.
ADOPTED by the OTS Board of Directors at its Meeting on June 28, 2017.