The Blood Cancer Foundation of Michigan requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of The Blood Cancer Foundation of Michigan, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that The Blood Cancer Foundation of Michigan can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees and volunteers to report concerns about violations of The Blood Cancer Foundation of Michigan’s code of ethics or suspected violations of law or regulations that govern The Blood Cancer Foundation of Michigan’s operations.

No Retaliation

It is contrary to the values of The Blood Cancer Foundation of Michigan’s for anyone to retaliate against any board member, officer, employee or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of The Blood Cancer Foundation of Michigan. 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.

Reporting Procedure

The Blood Cancer Foundation of Michigan has an open-door policy and strongly recommends that employees share their questions, concerns, suggestions or complaints with their supervisor. If an employee is not comfortable speaking with his or her supervisor or is not satisfied with the supervisor’s response, you are encouraged to speak with the President of the organization.

Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to The Blood Cancer Foundation of Michigan’s Compliance Officer, 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, the President or the organization’s Compliance Officer.

Compliance Officer

The Blood Cancer Foundation of Michigan’s Compliance Officer is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Compliance Officer will advise the President of all complaints and their resolution and will report at least annually to the Treasurer on compliance activity relating to accounting or alleged financial improprieties.

Accounting and Auditing Matters

The Blood Cancer Foundation of Michigan’s Compliance Officer shall immediately notify the Finance Committee of any concerns or complaint regarding corporate accounting practices, internal controls or auditing and work with the committee until the matter is resolved.

Acting in Good Faith

Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.  Accordingly, employees and others have the right to disclose, in confidence, trade secrets to federal, state, and local government officials, or to an attorney, for the sole purpose of reporting or investigating a suspected violation of law. Employees have the right to disclose trade secrets in a document filed in a lawsuit or other proceeding, but only if the filing is made under seal and are protected from public disclosure. Nothing in this Policy is intended to conflict with the Defend Trade Secrets Act (18 U.S.C. § 1833(b)).

Handling of Reported Violations

The Blood Cancer Foundation of Michigan’s Compliance Officer will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation.  All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

Compliance Officer:

Policy approved by the Board of Directors