Whistle Blower Policy

Reporting Responsibility

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that NHAA can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees and volunteers to report concerns about violations of NHAA’s code of ethics or suspected violations of law or regulations that govern NHAA’s operations. Examples include: theft or financial reporting that is intentionally misleading; improper or undocumented financial transactions; improper destruction of records; improper use of assets; and violations of NHAA’s conflict-of-interest policy.

Notice of Policy

This Whistleblower Policy will be posted on the Member Portal of NHAA’s website and it will be distributed to the NHAA’s staff.

No Retaliation

It is contrary to NHAA’s values for anyone to retaliate against any board member, officer, employee or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of NHAA. 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. Examples of the types of punishment from which board members, officers employees and volunteers must be protected include firing, demotion, suspension, harassment, failure to consider the employee for promotion, or any other discrimination.

Reporting Procedure

NHAA has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with a member of the Board of Directors. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the NHAA Board which has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or member of the Board. Concerns or complaints will be referred to the appropriate Compliance Officer for investigation.

Handling of Reported Violations

NHAA’s Compliance Officer will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

Investigation Procedure

The NHAA Board of Directors is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. After the investigation has been completed, the NHAA will not consider the whistleblower issue closed until either the problems revealed by the investigation have been addressed or the organization can explain to the affected stakeholders why corrective action is not necessary.

Compliance Officer for Non-financial Concerns

The NHAA Vice President is the Compliance Officer responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved, other than those involving Financial Matters, which are the compliance responsibility of the Treasurer. The Vice President will advise the President of all complaints and their resolution and will report at least annually to the Board of Directors on compliance activity on Non-financial Matters.

Compliance Officer for Financial Matters

The NHAA Treasurer is the Compliance Officer responsible for ensuring that all complaints or concerns regarding accounting practices, alleged financial improprieties, internal controls or auditing are investigated and resolved. The NHAA Treasurer shall immediately notify the Board of any concerns or complaints regarding accounting practice, alleged financial improprieties, internal controls or auditing and work to resolve any issues. and will report at least annually to the Board on compliance activity relating to Financial Matters.

Acting in Good Faith

Anyone filing a written 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. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly 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. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Compliance Office for Non-financial Concerns: Linda McLear, NHAA Vice President . Complaints can be sent to lakmclear@gmail.com.

Compliance Office for Accounting and Auditing Matters: Kenneth Cohen, NHAA Treasurer. Complaints may be sent to kennethscohen@gmail.com.

Policy adopted by the Board of Directors on June 13, 2020.