Whistleblower protection policy

Purpose

To create a culture and environment of openness and transparency that encourages and enables employees and volunteers to raise allegations of wrongdoing within CPhA without fear of reprisal.

The intent of this policy is to provide an effective process for addressing allegations of wrongdoing within CPhA internal and external operations.

Policy

CPhA has a Personal Conduct Policy that outlines the standards of business and personal ethics, which employees and volunteers must follow in the conduct of their work duties and responsibilities. Employees and representatives of CPhA must act with honesty and integrity in fulfilling their responsibilities, and comply with all applicable laws and regulations. In line with this commitment, and as reflected in the CPhA Open-Door Policy , CPhA embraces a working environment that fosters open communication, one in which employees and volunteers have an avenue to raise concerns of a serious nature without fear of reprisal or victimization.

Alleged wrongdoings include financial matters (accounting practices, internal controls, financial reporting), procurement matters and any unethical, illegal or improper conduct that cannot or has not been managed appropriately.

Anyone raising an allegation under this policy must be acting in good faith and have reasonable grounds for believing the information disclosed is a true and serious wrongdoing. Any allegations that prove to be unsubstantiated and made maliciously, or are knowingly false, will be viewed as serious disciplinary offences. No employee or volunteer who reports an allegation in good faith shall suffer harassment, retaliation or adverse employment consequence.

An employee who retaliates against someone who has reported a concern in good faith is subject to discipline up to and including dismissal.

Procedures for Raising and Investigating Concerns Raising Concerns

Serious concerns should be reported to:

As per the process identified in “Investigative Concerns” below, the complaint or allegation must be in writing via either a letter or email and should include the following information:

Name of complainant (optional)
Description of the wrongdoing
Date complainant became aware of the wrongdoing.
Individual(s) suspected of the wrongdoing.
Steps taken (if any) prior to making the complaint or allegation (e.g., spoke with supervisor)

CPhA Mailing Address:

Canadian Pharmacists Association
851 Industrial Avenue
Mailbox M035
Ottawa, ON K1G 4L3

Complainants may remain anonymous if they so desire. However, in order to allow for a better investigation, complainants should consider identifying themselves when making a complaint or allegation. They can be assured that the substance of the complaint will be treated with utmost confidentiality, and will not be discussed with others except to the extent necessary to conduct a complete and fair investigation. In all cases, the person who is alleged to have committed the infraction will be made aware of the complaint at an appropriate point during the investigation.

Although the complainant is not expected to prove the truth of an allegation, the complainant needs to provide sufficient evidence to the person contacted in order to show that there are sufficient grounds for concern. The extent of contact between the complainant and the body investigating the concern will depend on the nature of the issue and the clarity of information provided. The investigating body may seek further information from the complainant. Subject to legal and confidentiality constraints, the complainant will receive information about the outcome of any investigations.

Investigating Concerns

All concerns will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation.

The CEO should be the first point of contact and is responsible for investigating and resolving most types of reported complaints and allegations. In certain circumstances, the CEO may refer the matter to, or seek assistance from, employees or others depending upon the nature of the complaint or allegation. However, under no circumstances will a matter be referred to an employee or other person who is the subject of the complaint or allegation, or is otherwise an inappropriate person to assist with the investigation.

The CEO is required to report to the Finance, Audit and Risk Management Committee twice annually on complaints and summary results of investigations, as a standing item on the agenda of committee meetings.

The Finance, Audit and Risk Management Committee shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The CEO shall immediately notify the Chair of the Finance, Audit and Risk Management Committee of any such complaint received. The Chair may, at his/her discretion, call a committee meeting to discuss the matter, and in any event shall disclose the substance of the complaint or allegation at the next regularly scheduled committee meeting. The Committee may then, by majority vote, commence an investigation of the complaint or allegation, or transfer such investigation to another appropriate investigator. The Committee or other investigator may enlist the assistance of one or more employees and outside legal, accounting or other advisors, as may be appropriate to conduct the investigation.

If the complaint or allegation concerns the CEO or a member of the Board of Directors, it should be directed immediately to the Chair of the Finance, Audit and Risk Management Committee. The Chair of this committee may then commence an investigation of the complaint or allegation, or transfer such investigation to another appropriate investigator. The Chair or other investigator may enlist the assistance of one or more employees and outside legal, accounting or other advisors, as may be appropriate to conduct the investigation If the complaint or allegation concerns the Chair of the Finance, Audit and Risk Management Committee, the complaint should be directed immediately to the Chair of the Board who shall follow the procedures noted above.