Whistleblowing

Policy

Camino is committed to the highest possible standards of openness, integrity, and accountability and we keep the people we serve at the centre of our work. To ensure we achieve these standards, we maintain a formal process that enables employees, students, volunteers and members of the community to raise serious concerns to Management and the Board of Directors about any aspect of Camino's work. We encourage individuals to voice their concerns as soon as possible, even when it might be difficult to do so.

The Whistleblowing policy covers serious concerns that fall outside the scope of operating policies and procedures. Examples of whistleblower incidents include, but are not limited to, the following:

1. Conduct which is an offence or a breach of law
2. Broad or significant health and safety risks, including risks to the public or to employees of the organization that have not been resolved through other processes
3. Misrepresenting program budget, ‘side deals’ or ‘under the table’ dealings with contractors for personal benefit
4. Receiving personal kickbacks or gifts from contractors or vendors, which could create bias in the tendering process
5. Possible fraud and/or corruption such as inappropriate recording or reporting of revenues and expenses
6. Inappropriate classification of assets and/or liabilities
7. Embezzlement of agency assets
8. Sexual or physical abuse of persons we support
9. Other unethical conduct

Concerns from employees, students and interns about matters that are of a more operational nature are reported through the “Employee Conflict and Complaint Resolution” policy. Concerns from program and service participants about the service they have received are managed through the Client Complaint and Resolution Policy.

Reporting a whistleblower concern/incident in good faith and without malicious intent is protected at Camino. The reporter will not face discharge, demotion, suspension, withholding of services or any other manner of discrimination regardless of the investigation's outcome.

However, making a frivolous, malicious, or personally motivated allegation may result in disciplinary action.
To the extent possible, a report will remain confidential; however, there may be limits to that confidentiality depending on the issue at hand. Such limits will be discussed with the reporter.

Procedures

Reporting your Concern

Report your concern to one of Camino’s Directors unless the concern involves another Director; concerns involving a Camino Directors should be reported directly to the CEO. If your concern is about the CEO or a member of the Board of Directors, report your concern (or that you have a concern to discuss) to the Board Chair and Board Vice Chair via the Board’s email address: Board@caminowellbeing.ca.

Concerns may be raised orally or in writing. For those made orally, the person who receives the report (“the responsible person”) will document the concerns in writing and ask the reporter to confirm accuracy. An individual who wishes to make a written report must include the following details:

• The background and history of the concern (giving relevant dates).
• The reason they are particularly concerned about the situation.

The reporter is encouraged to include their name with the allegation whenever possible. Concerns expressed anonymously are much less powerful and may not be able to be fully investigated. Anonymous concerns will be considered at the discretion of Camino. In exercising this discretion, factors that will be considered include:

• The seriousness of the issues raised
• The credibility of the concern
• The likelihood of confirming the allegation from appropriate sources

It is important to note that

• The earlier a concern is reported, the easier it is to act.
• Although the reporter is not expected to prove beyond doubt the truth of an allegation, they will need to demonstrate that there are reasonable grounds for their concern.
• The reporter may invite their trade union, professional association representative, or a support individual to be present during any meetings or interviews about the concerns they have raised.

How Camino Will Respond

Initial enquiries will be made to determine whether an investigation is appropriate and, if so, what form it should take. The overriding principles at Camino are the public interest and the safety of all individuals. Depending on the nature of the reported concern, it may be:

• investigated by management, or the Board, or through the disciplinary process

• referred to the police

• referred to the external auditor or to an independent investigator If urgent action is required related to public interest and safety, this will be taken before any investigation is conducted.

Within 5 working days of a concern being raised, the responsible person will write to the reporter acknowledging that the concern has been received.

Within 10 working days of a concern being raised, the responsible person will write to the reporter outlining:

• how Camino proposes to deal with the matter.

• the estimated time to provide a final response.

• any support mechanisms for the reporter.

• whether further investigations will take place; and if not, explaining why.

Camino will take steps to minimize any difficulties the reporter may experience because of raising a concern. For instance, if the reporter is required to give evidence in criminal or disciplinary proceedings, Camino will arrange for the reporter to receive advice about the process. Other actions may be taken to support reducing stress associated with making the report, such as arranging meetings to be held off site if appropriate.

The responsible person will, if and as needed, have a discussion with the reporter about the limits of confidentiality, communicate what the limits are in the instance at hand, and articulate how any concerns of the reporter may be addressed.

Camino recognizes that the reporter needs to be assured that the matter has been properly addressed. Thus, subject to legal constraints, Camino will inform the reporter of the outcome of any investigation.

How the Matter May be Taken Further

This policy is intended to provide individuals an avenue within Camino to raise concerns. If the reporter is not satisfied with the action taken and feel it is appropriate to take the matter outside Camino, possible contacts include:

• The external auditor
• The police
• The reporter’s union
• Relevant professional bodies or regulatory organizations
• A relevant voluntary organization

If the Whistleblower does take the matter outside Camino, they should ensure they do not disclose confidential agency information.