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WHISTLEBLOWER POLICY
TMCF defines a whistleblower as a team member or agent of TMCF who
reports an activity that he or she considers to be dishonest, ethically
questionable or potentially illegal to one or more of the parties specified
in this policy. The whistleblower is not responsible for investigating the
activity in question, assessing fault or undertaking corrective measures, if
any. Appropriate personnel within TMCF shall have the responsibility for
investigating such claims, including, without limitation, the general counsel
and the human resources department. Examples of dishonest, ethically
questionable or potentially illegal activities may include violations of federal,
state or local laws; billing for services not performed or for goods not
delivered; misuse or misappropriation of organizational funds or property; and fraudulent financial reporting.
If a team member has knowledge of or a concern about dishonest, ethically questionable or potentially illegal activity, the team member should contact his or her supervisor, the general counsel or Human Resources. However, team members must exercise sound judgment to avoid baseless allegations. A team member who knowingly or intentionally files a false report of wrongdoing may be subject to discipline, up to and including termination.
Whistleblower allegations will be held in confidence and, to the extent possible, the identity of the whistleblower will be kept confidential. However, the identity of the whistleblower may have to be disclosed to conduct a thorough investigation, comply with applicable laws or provide accused individuals their legal recognized rights of defense. In addition, TMCF will not retaliate against a whistleblower.
This includes, without limitation, protection from retaliation in the form of an adverse employment action such as termination, compensation decreases or poor work assignments and threats of physical harm. Any whistleblower who believes he or she is being retaliated against must contact the human resources department immediately. The right of a whistleblower for protection against retaliation does not, however, include immunity from any personal wrongdoing that is alleged or discovered during the underlying investigation.
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