Whistleblower Policy
Deon Policy Institute (“DPI”) is committed to conducting its business in a lawful and ethical manner. This whistleblower policy is intended to encourage and enable DPI’s employees and personnel to report serious concerns regarding illegal or unethical conduct with DPI’s activities.
Examples of conduct that should be reported include, but are not limited to, the following acts or practices:
That constitute fraud;
That may lead to incorrect financial reporting;
That are unlawful in any way, such as various forms of harassment or discrimination toward other employees or the populations that DPI serves;
That constitute improper conduct, such as misuse of DPI property, accepting expensive business gifts or disclosing proprietary information; and
That include, but is not limited to, suspected violations of DPI’s employee handbook and other DPI policies (e.g., the conflict of interest policy, or the research independence policy).
While this policy generally relates to suspected misconduct in the course of DPI’s business, DPI may also review allegations of suspected misconduct by employees and personnel in work or activities outside of DPI.
Employees and personnel should exercise sound judgment in assessing the validity of the suspected misconduct before reporting it and must report their concerns in good faith. It is a violation of this policy to maliciously or knowingly file a false report of suspected misconduct.
Violations of this policy or other misconduct may lead to discipline, up to and including termination of employment and/or affiliation with DPI.
Reporting Suspected Violations
Employees and personnel should report violations, suspected or actual, to their supervisor or the corporate secretary. Regardless of severity, individuals may report any matter or address any questions regarding this policy to DPI’s legal counsel.
When reporting actual or suspected misconduct, employees and personnel should provide as much information as possible, including:
The individual(s) involved in the violation;
The nature of the violation;
The DPI policies or law that you believe is being violated; and
The evidence that leads you to believe that a violation has occurred.
Investigation
DPI will undertake a prompt investigation, with a scope and design as may be appropriate under the circumstances. The steps to be taken during the investigation will vary depending upon the nature of the allegations. For additional information regarding the investigation process for research misconduct, please see the Plagiarism and research misconduct policy.
Reports or incidents warranting confidentiality will be handled appropriately and information will be disclosed to others only on a need-to-know basis. DPI cannot guarantee, however, absolute confidentiality.
Upon completion of the investigation, DPI will take appropriate remedial action, as necessary and supported by the facts. DPI, in its sole discretion, will determine the appropriate individuals to notify upon completion of the investigation.
Non-Retaliation
DPI will use its best efforts to protect a whistleblower’s identity to the extent possible and practical. However, a whistleblower’s identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defense. Individuals are strongly encouraged to discuss allegations openly and face-to-face.
Neither DPI nor any individuals affiliated with DPI will retaliate against an individual who, in good faith, reports suspected misconduct or participates in a related investigation. Employees and personnel who believe that they have been retaliated against for reporting suspected misconduct or participating in an investigation of such conduct should promptly contact DPI’s President or legal counsel.