Lawndale Christian Health Center

Policy Name: Whistleblower and Non-Retaliation Policy Com munit Effective Date December 2009 Policy Number Review Date December 2013 Authorization y Approval Date December 2009 Board President Healt Revised: h Cente Community Health Centers of Greater Dayton requires board members, officers, and rs of employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of CHCGD must practice honesty and Great integrity in fulfilling responsibilities and comply with all applicable laws and regulations. er Dayto Community Health Centers of Greater Dayton reserves the right to change or amend this policy n at any time as may be deemed necessary. Policy Typ Policy e: It is the responsibility of all board members, officers, and employees to comply with and to Hu report violations or suspected violations of the Code of Ethics, CHCGD policies, licensing man standards, OHSA violations, or any other laws in accordance with this policy. Reso urce This policy is intended to encourage and enable employees and others to raise serious concerns s within the Company prior to seeking the assistance of a third party.

Procedure:

No Retaliation

No Board member, officer, or employee who in good faith reports a violation of the Code, CHCGD policies, or law will suffer harassment, retaliation or adverse employment consequence.

An employee who retaliates against someone who has reported a violation in good faith is subject to disciplinary action up to and including termination.

Reporting Violations

Board members, officers and employees should share their questions, concerns, suggestions and complaints with someone who can address them properly. This should be either the Compliance Officer or the Executive Director. If an employee is not comfortable speaking with the Executive Director or is not satisfied with the response, that employee may speak with Human Resources or a member of the Board of Directors.

of 2 Acting muse be acting in good faith and have reasonable grounds for believing the information in disclosed is a violation of the Code, Company policy or the law. Any allegations that prove not Good to be substantiated and have been made with malicious intent or with knowledge that they were Faith false will be address through the disciplinary action process.

Any Confidentiality good faith CHCGD will, to the extent possible, protect the confidentiality of the complainant of any good report, faith report. Reports of violations or suspected violations will be kept confidential (a need-to- concer know basis) in order to conduct an adequate and unbiased investigation. n or compla Handling of Reported Violations int is fully All reports will be promptly investigated and appropriate disciplinary action will be taken if protect warranted by the investigation. The complainant will be informed that follow up has or is ed by occurring within two weeks after the complaint has been received, but will not be told of any this disciplinary action that may have occurred. policy, even if the report, questio n or concer n is later not substan tiated throug h the investi gation process .

Anyon e filing a compla int concer ning a violati on or suspect ed violati on