Speaking up Policy Template

Speaking Up Policy (Customizable template)

[Acme Company’s] Speaking Up Policy

Policy Audience and Expectations [Acme] expects its employees to report non-compliance with laws, company policy, and the company Code of Conduct. Speaking up protects [Acme], its employees, and its stakeholders.

This policy outlines the standards and procedures by which [Acme] employees should report instances of non-compliance. [Acme] employees at every level, in every department, and at every location have a responsibility to speak up when they believe they have knowledge of the company or one of its employees being out of compliance. If you observe non- compliance first hand, speak up; if you suspect non-compliance, speak up.

Why speak up? Examples of Issues to Report [Acme] is committed to speaking up because it is the best way to foster a culture of trust and detect instances of non-compliance that may harm the reputation and the continued success of our company. Employees should speak up about all violations or suspected instances of violations including, but not limited to instances of:  Fraud  Bribery and inappropriate giving or receiving of gifts  Inappropriate financial and accounting records  Discrimination  Harassment  Environmental, health, and safety violations  [insert other high-risk areas]

Self-Reporting If you believe that you have been personally involved in an instance of non-compliance, you are still expected to speak up; it is better to self-report than to be the subject of another person’s allegation. [Acme] will consider the situation fully when deciding if disciplinary action is necessary.

Non-Retaliation Statement Employees should feel comfortable reporting issues of non-compliance. Retaliation of any type against an employee who brings forward a concern in good faith will not be tolerated. Anyone who attempts to retaliate against an employee for speaking up will face discipline, which may include termination. If you suspect retaliation against yourself or any [Acme] employee for speaking up, report your concern.

Confidentiality [Acme] respects confidentiality and will protect the identity of any employee who brings a concern forward in good faith. Relevant information will be shared on a “need to know” basis only with individuals responsible for investigating and resolving the concern.

1 Reporting Channels [Acme] offers several channels for speaking up. Use the channel with which you are most comfortable, starting with your manager. Other speaking up channels include  Another manager or supervisor  Your Compliance department representative  The Legal department  [insert company helpline name and number]

Expectations of Managers Every manager who receives a report is expected to treat the concern or allegation with discretion, and to treat the employee who brought the concern forward with respect. The manager is expected to escalate this concern according to the company’s escalation criteria.

Manager Pushback If you report a concern of non-compliance and are told to “keep quiet” by your manager, you should immediately contact your Compliance representative or the helpline to report the concern as well as the manager’s pushback.

Investigations Process When an employee raises a concern, [Acme] investigates the facts to determine objectively what has happened; no one is judged to be “guilty” before this investigation is complete. [Acme] Compliance will work with the Legal and Compliance departments to determine how best to investigate and resolve the matter. The privacy of the reporting employee will be respected; confidential information will be shared only on a “need to know” basis.

What should you expect after reporting a concern? It is possible that the reporting employee may not be involved in the investigation after bringing his or her concern forward. However, [Acme] takes all reports of non-compliance seriously; [Acme] employees should expect that all reports are taken seriously and investigated appropriately.

Board Reporting The Compliance department will report to the Board periodically on cases of non-compliance brought forward by [Acme] employees.

Questions? If you have questions about the policy, please:  Speak to your manager  Visit the [Acme] Compliance website  Contact your Compliance representative  Call the [Acme] hotline  [insert other available channels]