Whistleblower Policy

ST. PATRICK’S DAY PARADE, INC.
Whistleblower Policy

St. Patrick’s Day Parade, Inc. (the “Organization”) is committed to complying with state statutory requirements that provide appropriate protections for its employees who are whistleblowers. The Organization requires directors, officers, volunteers and employees (“Reporting Individuals”) to act in accordance with all applicable laws, regulations, and policies, and to observe high standards of business and personal ethics in the conduct of their duties and responsibilities.

Purpose
The purpose of the Whistleblower Policy is to define whistleblowing in the context of this policy, set forth the steps taken by employees making whistleblower complaints and delineate the steps that shall be taken by the Organization to protect employees engaged in whistleblowing, and to establish a procedure for making whistleblowing disclosures.
The objectives of this Policy are to establish policies and procedures to:
• Prevent or detect, and correct, improper activities;
• Encourage each Reporting Individual to report any action or     suspected action concerning the Organization that he or she in good faith believes to be illegal, fraudulent, a violation of law, a violation of a policy of the Organization, or a questionable accounting or auditing matter;
• Ensure the receipt, documentation, retention of records, and resolution of reports received under this Policy; and
• Protect Reporting Individuals from intimidation, harassment, discrimination or other retaliatory action or, in the case of employees, adverse employment consequences.
Whistleblower Protection and Definition
The Organization shall take no retaliatory action against an employee because the employee does any of the following:
A. Discloses, or threatens to disclose to a supervisor or to a public body an activity, policy or practice of the employer, or another employer, with whom there is a business relationship, that the employee reasonably believes:
i. Is in violation of a law, rule or regulation promulgated pursuant to law, including any violation involving deception of, misrepresentation to, any shareholder, investor, client, patient, customer, employee, former employee, retiree or pensioner of the employer or any governmental entity, or, in the case of an employee who is licensed or certified health care professional, reasonably believes constitutes improper quality of patient care; or
ii. Is fraudulent or criminal, including activity, policy or practice of deception or misrepresentation which the employee reasonably believes may defraud any shareholder, investor, client, patient, customer, employee, former employee, retiree or pensioner of the employer or any governmental entity;
B. Provides information to, or testifies before, any public body conducting an investigation, hearing or inquiry into any violation of law, or a rule or regulation promulgated pursuant to law by the employer, or another employer, with whom there is a business relationship, including any violation involving deception of, or misrepresentation to, any shareholder, investor, client, patient, customer, employee, former employee, retiree or pensioner of the employer or any governmental entity, or, in the case of any employee who is a licensed or certified health care professional, provides information to, or testifies before, any public body conducting an investigation, hearing or inquiry into the quality of patient care; or
C. Objects to, or refuses to participate in any activity, policy or practice which the
employee reasonably believes:
i. Is in violation of a law, rule or regulation promulgated pursuant to law, including any violation involving deception of, misrepresentation to, any shareholder, investor, client, patient, customer, employee, former employee, retiree or pensioner of the employer or any governmental entity, or, in the case of an employee who is licensed or certified health care professional, reasonably believes constitutes improper quality of patient care;
ii. Is fraudulent or criminal, including activity, policy or practice of deception or misrepresentation which the employee reasonably believes may defraud any shareholder, investor, client, patient, customer, employee, former employee, retiree or pensioner of the employer or any governmental entity; or
iii. Is incompatible with a clear mandate of public policy concerning the public
health, safety or welfare or protection of the environment.
Procedures for Making Disclosures
A. Each Reporting Individual has an obligation to report concerns as soon as such concerns are detected. The types of concerns that should be reported include, for purposes of illustration and without being limited to, the following:
• Providing false or misleading information on the Organization’s financial documents, tax returns, charitable solicitations or other public documents;
• Providing false information to, or withholding, material information from the Organization’s auditors, accountants, lawyers, directors or other representatives responsible for ensuring the Organization’s compliance with fiscal and legal responsibilities;
• Embezzlement, private benefit, or misappropriation of funds;
• Material violation of any other of the Organization’s policies;
• Discrimination based on race, gender, sexual orientation, ethnicity, and disability;
• Facilitation or concealing any of the above or similar actions.
B. Anyone reporting a concern must act in good faith and have reasonable grounds for believing the matter raised is a serious violation of law or policy or a material accounting or auditing matter. The act of making allegations that proves to lack reasonable grounds, or to have been made in bad faith, maliciously, recklessly, with gross negligence, or with the knowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in discipline, up to and including dismissal from the position or termination of employment.
C. Depending on circumstances, such conduct may also give rise to other actions, including
civil or criminal lawsuits.
D. Except as otherwise provided for herein, any employee shall make a written disclosure to
the designated member of the Board of Directors:

Name: Ryan E. Hanlon, Esq. Telephone: (212) 789-3108 Email: rhanlon@riemerlaw.com Address: Riemer & Braunstein LLP
Seven Times Square, 25th Floor New York, NY 10036

If the Reporting Individual perceives it to be a conflict of interest or does not otherwise feel comfortable reporting concerns to the designated member of the Board of Directors, then the Reporting Individual shall instead direct a written disclosure to the Chairman of the Board of Directors:

Name: Dr. John L. Lahey Telephone: (203) 582-8700 Address: St. Patrick’s Day Parade, Inc.
P.O. Box 295, Woodlawn Station Bronx, NY 10470

A written disclosure should include as much specific, factual information as possible to allow for proper assessment of the nature, extent, and urgency of the matter that is the subject of the disclosure.
E. In cases where the supervisor is contacted by an employee making a disclosure, he or she
shall notify the designated member of the Board of Directors.
F. A confidential investigation will be promptly conducted by the designated official, at the conclusion of the investigation, a report will be issued and appropriate action will be taken where the allegations are verified and/or otherwise substantiated.
Written Notice Required Under Certain Circumstances
The protection against retaliatory action shall not apply to an employee who makes a disclosure to the Organization’s Board of Directors or any public agency, authority or body unless the employee has first brought the matter to the attention of a supervisor of the employee or the designated official or agent by written notice and has afforded the Organization a reasonable opportunity to correct the matter. In an emergency situation, this requirement of written notice to a supervisor or designated official or agent shall be waived when the employee is reasonably certain the matter is known to one or more supervisors at the Organization or when the employee reasonably fears physical harm as a result of the disclosure.
Distribution and Posting Notices
The Organization shall post this policy on its webpage and in its office. The Organization shall also conspicuously display notices of its employees’ protections, obligations, rights and procedures under this act, shall annually distribute written or electronic notices to all employees, and shall use other appropriate means to keep its employees informed of protection. Each notice posted or distributed pursuant to this section shall include the name of the person the Organization has designated to receive written notifications pursuant to this policy. The Organization shall distribute to each director, officer and employee and to each volunteer a copy of this Whistleblower Policy as then in effect (a) when such person first becomes director, officer or employee or first provides substantial services; (b) on or about January 1 of each calendar year; and (c) within 30 days after the effective date of any material change of this Whistleblower Policy.

Share This