CAC Whistleblower Policy And Procedures.pdf

# CAC Whistleblower Policy and Procedures Summary

Purpose: Capitalize Albany Corporation (CAC) aims to protect employees who report ethical violations or potential wrongdoing within the organization, fostering a culture of integrity without fear of retaliation.

Definitions:
- Good Faith: Information is disclosed in good faith when the whistleblower genuinely believes it to be true and constitutes potential wrongdoing.
- CAC Employee: Includes all board members, officers, staff (full-time, part-time, contract, probationary, or temporary), and temporary employees.
- Whistleblower: Any CAC employee who reports wrongdoing in good faith, concerning another employee or the corporation's business.
- Wrongdoing: Corruption, fraud, criminal activity, misconduct, waste, conflict of interest, false reporting, or abuse of authority by a CAC employee related to the company.
- Personnel Action: Any employment-related decision affecting compensation, position, transfer, assignment, reinstatement, or performance evaluation.

Reporting Wrongdoing (Section 1):
CAC employees must report potential wrongdoing orally or in writing to their supervisor, the Board Chairman, or general counsel. Prompt reporting is essential, and while confidentiality is maintained, whistleblowers may also disclose information to relevant authorities if they fear retaliation or ineffective internal reporting.

No Retaliation or Interference (Section 2):
- Whistleblowers are protected from harassment, retaliation, or adverse action for reporting potential wrongdoing in good faith.
- CAC strictly prohibits any form of retaliation or interference with disclosure efforts.
- Allegations of retaliation will be thoroughly investigated, and offenders may face termination.
- These procedures do not limit existing legal rights against retaliation under New York state laws like Civil Service Law § 75-b, Labor Law § 740, and State Finance Law § 191 (False Claims Act). Employees should inform their appointing authority before external disclosure to preserve these rights.