Whistleblower Policy
General
The Veterans Medical Research Foundation (VMRF) requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of VMRF, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
Reporting Responsibility
It is the responsibility of all directors, officers and employees to report ethics violations or suspected violations in accordance with this Whistleblower Policy. Communication of this document to all employees will be done on an annual basis through e-mail notification.
No Retaliation
No director, officer or employee who in good faith reports an ethics violation shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within VMRF prior to seeking resolution outside of VMRF.
Reporting Violations
VMRF has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor is in the best position to address an area of concern. However, if the employee is not comfortable speaking the employee’s supervisor or is not satisfied with the supervisor’s response, the employee is encouraged to speak with someone in the Human Resources Department or anyone in management. The Chief Human Resources Officer will serve as the Compliance Officer for VMRF. Supervisors and managers are required to report suspected ethics violations to the VMRF’s Chief Human Resources Officer, who has specific and exclusive responsibility to investigate all reported violations. For suspected fraud, or when the employee is not satisfied or is uncomfortable following VMRF’s open door policy, the employee should contact VMRF’s Chief Human Resources Officer directly. If the employee is not comfortable speaking with someone in management or in the Human Resources Department, the employee is urged to contact the President of the VMRF Board of Directors or a member of the VMRF Audit Committee.
Chief Human Resources Officer
VMRF’s Chief Human Resources Officer is responsible for investigating and resolving all reported complaints and allegations concerning violations and, at his/her discretion, shall advise the CEO and/or the Audit Committee. The Chief Human Resources Officer has direct access to the Audit Committee of the Board of Directors and is required to report to the Audit Committee at least annually on compliance activity.
Accounting and Auditing Matters
The Audit Committee of the board of directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The Chief Human Resources Officer shall immediately notify the Audit Committee of any such complaint and work with the committee until the matter is resolved.
Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Only legally obtained materials may be submitted as part of a report following this Whistleblower policy. Making allegations that prove not to be substantiated and that prove to have been made maliciously or were known to be false will be viewed as a serious disciplinary offense.
Confidentiality
Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously to the Chief Human Resources Offier, CEO, or President of the VMRF Board of Directors. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
Handling of Reported Violations
The Chief Human Resources Officer will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days, unless the report was received anonymously. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.
Chief Human Resources Officer:
Maria Sittmann, MBA
Veterans Medical Research Foundation
3350 La Jolla Village Dr. (151A)
San Diego, CA 92161
Office: 858.552.8585. 4. ext 3375
Office Direct: 858.642.3375
Fax: 858.642.3081
msittmann@vmrf.org
President of the Board:
Roger Spragg, M.D.
Veterans Medical Research Foundation
3350 La Jolla Village Dr. (151C)
San Diego, CA 92161
Office: 858.552.8585 ext 1248
rspragg@ucsd.edu
CEO:
Kerstin Lynam, MBA
Veterans Medical Research Foundation
3350 La Jolla Village Drive (151A)
San Diego, CA 92161
Office: 858.552.8585 ext 3070
Office Direct: 858.642.3070
Fax: 858.642.3499
klynam@vmrf.org
Audit Committee Chair:
Ronald Larson
Chief Financial Officer, VA San Diego Healthcare System
3350 La Jolla Village Drive (04)
San Diego, CA 92161
Office: 858.552.8585 ext 3351
Fax: 858.642.6215
ronald.larson@va.gov
Other Veterans Medical Research Foundation Management Staff
Barbara Dovenbarger, CFO
Beth Bieger, Contracts & Grants Manager
Caryl Finch, Post Award Contracts & Grants Manager
Bob Millington, IT Director
Eileen Vinnola, Accounting Manager
Approved by the VMRF Board of Directors: August 11, 2009