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225: Reporting and Response Procedures

Scope

This policy applies to all EVAWI representatives including Staff, Officers, Directors, Associates, Committee Members, Honorary Members, Subrecipients, Consultants, Contractors, Volunteers, Allies, and Constituents (collectively referred to as “Members”).

Purpose

Members are required to observe the highest standards of business and personal ethics in the conduct of their duties and responsibilities. All Members have a responsibility to promote a work environment that is safe, inclusive, and respectful. As representatives of the EVAWI, Members must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations.

Reporting Responsibilities

Members are required to report violations, or suspected violations, in accordance with this policy, so that issues can be investigated in a timely and confidential manner, when warranted.

If a Member experiences or observes behaviors that might constitute a violation of any EVAWI policy, safety guidelines, relevant laws, or ethical standards governing Member conduct, those concerns should be reported to the individual’s immediate or to the Chief Executive Officer (CEO). The CEO, or depending on the circumstances, a designee, shall be responsible for investigating and resolving all reported complaints and allegations concerning any Member, other than the CEO or a member of the Board of Directors.

Violations or suspected violations by the CEO, or a Board Member, shall be reported to the Executive Committee as soon as practically possible. The Executive committee is responsible for investigating and resolving all reported complaints and allegations against the CEO or a Board member.

Members are encouraged to talk to their immediate supervisor or the CEO, if there are any questions about any of EVAWI’s policies, safety guidelines, relevant laws, or ethical standards.

Acting in Good Faith

Any Member who reports behavior that could potentially constitute a violation of EVAWI policies must be acting in good faith and have reasonable grounds for believing the

1 End Violence Against Women Effective Date: 11/18/2008 International Revision Date: 08/14/2019 Review Date: 08/14/2019

225: Whistleblower Reporting and Response Procedures

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, which may result in discipline up to and including termination or removal from the Board of Directors.

Retaliation

EVAWI policies are intended to encourage and enable Members to raise concerns within the , prior to seeking resolution outside the organization. No Member who in good faith asks questions or raises concerns about conduct, or reports a suspected violation, shall suffer harassment, retaliation or adverse consequence as a result.

Any Member who retaliates against anyone who has reported a violation (or suspected violation) in good faith, is subject to discipline up to and including termination or removal from the Board of Directors.

Confidentiality and Corrective Action

To the extent possible, confidentiality shall be protected throughout the process of investigating a reported violation. However, it must be clear that a supervisor must report any complaint of fraud, violence, bullying, discrimination, or harassment to the CEO as soon as practically possible. Members must recognize that it may not be possible to keep an investigation completely confidential within the workplace, especially for a small organization such as EVAWI. Sometimes, an individual may want to simply notify a supervisor or the Board of Directors about an incident but ask that it be kept confidential and no corrective action taken. However, this is often not an option, because must immediately notify the CEO of certain reports, and a decision may be made by the CEO, or the Board of Directors, to investigate and take corrective action if warranted.

EVAWI will, however, strive to take Member’s concerns and wishes into account throughout the process of investigating and responding to a report, to the extent possible. For example, a Member will be asked about their wishes regarding corrective action. However, a supervisor or the CEO, may, or may not be able to honor those wishes. The safety and well-being of individual Members, as well as the safety and well- being of all Members, must be protected by responding appropriately to any complaints of possible violations so that appropriate action can be taken to deter any future fraud, discrimination, harassment, retaliation, or other misconduct.

Reporting Procedures

While Members may report a suspected violation to their immediate supervisor, the CEO, or in some cases, the Executive Committee, supervisors have a duty to report to

2 End Violence Against Women Effective Date: 11/18/2008 International Revision Date: 08/14/2019 Review Date: 08/14/2019

225: Whistleblower Reporting and Response Procedures

the CEO, if the behavior potentially constitutes a policy violation – particularly the policies on Workplace Violence, Intimidation, and Bullying (No. 530) and Discrimination or Harassment (No. 215).

If a Member’s grievance is against the CEO, or if for any reason a Member feels that a grievance cannot safely be made to the CEO, the Member shall notify any member of the Executive Committee – this includes the President, Vice President, Secretary, and Treasurer.

Accounting and Financial Violations

The Financial Review Committee shall address all reported concerns regarding corporate accounting practices, and internal controls of the Organization. The Chair of the Financial Review Committee will advise the Board of Directors of any concerns and work with the Financial Review Committee members until the matter is resolved.

Handling Reported Violations

If a report is made to the CEO (either directly or through a Member’s immediate supervisor), the Member will be notified within five business days, to acknowledge receipt of the reported or suspected violation.

If a report is made to the Executive Committee, or the Financial Review Committee (either directly or through the CEO) the respective Committee will acknowledge receipt of the report within five business days.

All reports will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation. The person who is named in the complaint will not be involved in the process of conducting the investigation or determining any corrective action.

Generally, an investigation will be completed within 90 calendar days. However, there may be circumstances where the process will take longer. If so, the Member making the report will be notified and the reasons for the delay explained.

When the investigation is completed, the Member who made the report will be informed of the outcome of the investigation, to the extent possible. However, information about any disciplinary action that might be taken is considered a personnel matter and therefore, confidential.

An appeal may be made to the Executive Committee if a Member is unsatisfied with the response of the CEO to a grievance, regardless of who was involved.

3 End Violence Against Women Effective Date: 11/18/2008 International Revision Date: 08/14/2019 Review Date: 08/14/2019

225: Whistleblower Reporting and Response Procedures

Federal Grant Conditions and the of Civil Rights

Because EVAWI is a recipient of federal funding, any Member who believes that he or she has experienced discrimination on the basis of actual or perceived race, color, religion, national origin, sex, gender identity, sexual orientation, or disability may file a complaint with the Office for Civil Rights (OCR), Office of Justice Programs, U.S. Department of Justice. OCR has authority to investigate complaints alleging a violation of the Violence Against Women Act (VAWA) nondiscrimination grant condition.

A complaint must generally be filed within one year from the date of the alleged discrimination. To file a complaint, download and complete the Complaint Verification Form (CVF) and Identity Release Statement (IRS) which are available from the website for the Office of Justice Programs, U.S. Department of Justice. These two forms should then be submitted to:

Office for Civil Rights Office for Justice Programs U.S. Department of Justice 810 7th Street, NW , DC 20531

OCR also accepts third-party discrimination complaints on behalf of individuals who are either unable or reluctant to file a complaint on their own behalf. The absence of a signed IRS from the aggrieved person may severely limit OCR’s ability to investigate a single incident of discrimination against an individual. However, the absence of a signed IRS will not prevent OCR from investigating an alleged discriminatory practice or policy.

Additional information about how to file a complaint with OCR is available on their website: http://www.ojp.usdoj.gov/about/ocr/complaint.htm

Fraud, Waste or of Federal Funds

Any potential fraud, waste, conflict of interest, bribery, gratuity, or similar misconduct relating to funds under any federal grant award shall be reported to a supervisor, the CEO, or the Executive Committee of the Board of Directors, as soon as practically possible.

The CEO, (or the Executive Committee, if the complaint involves the CEO) shall refer any credible evidence that a principal, employee, agent, subrecipient, contractor, subcontractor, or other person has, in connection with funds under any grant award, submitted a claim that violates the False Claims Act; or committed a criminal or civil violation of laws pertaining to a conflict of interest, fraud, bribery, gratuity, or similar misconduct to the U.S. Department of Justice:

4 End Violence Against Women Effective Date: 11/18/2008 International Revision Date: 08/14/2019 Review Date: 08/14/2019

225: Whistleblower Reporting and Response Procedures

Office of the Inspector General Investigations Division 950 Pennsylvania Avenue, N.W. Room 4706 Washington, DC 20530 [email protected] or (800) 869-4499

5 End Violence Against Women Effective Date: 11/18/2008 International Revision Date: 08/14/2019 Review Date: 08/14/2019

323 Workers' Compensation Effective Date: 01/12/2005 Revision Date: 8/14/2019, 12/14/2011 Review Date: 11/10/2017

Scope

EVAWI provides comprehensive workers' compensation insurance for full and part-time employees.

Purpose

Workers' compensation insurance typically covers the costs of medical treatment for workplace , and occupational . To qualify, injuries must arise out of, and occur as a result of, an individual’s . Occupational illnesses or must typically be caused or aggravated by the conditions of employment. Regardless of the type of occupational or illness, whether a claim is paid is determined by the workers’ compensation insurance provider, not EVAWI. However, if an employee is denied coverage, depending on the circumstances, EVAWI may be able to help an employee file an appeal to the insurance provider.

Workers’ Compensation Insurance Varies State to State

The State of Washington, Department of Labor and Industries, provides workers’ compensation insurance for Washington employers. EVAWI employees working in Washington are immediately enrolled in the state’s workers’ compensation insurance program when they are hired, and payments are made to the Department of Labor and Industries quarterly. Washington employers pay most of the cost of workers’ compensation insurance (approximately $.12 for every hour worked, an average of $18.00 per month per employee). EVAWI Washington employees pay a smaller percentage each month out of their paycheck (approximately $.07 for every hour worked, an average of $11.00 per month).

Remote Employees Working Outside Washington State

Every state has its own laws and regulations governing workers’ compensation and some are unclear as to whether out of state employers are required to provide workers’ compensation insurance. As a result, workers’ compensation insurance, the costs, and the options available, vary greatly across the country.

When a remote employee is hired, the Financial Manager will work with the CEO to evaluate the options for workers’ compensation insurance and if applicable, contact our insurance provider to ensure that the employee is covered by workers’ compensation insurance as soon as practically possible. Every effort shall be made to make sure that remote employees are covered by workers’ compensation insurance within 30 days of their date of hire. As of August 2019, EVAWI provides self-insured workers’

compensation insurance, and pays 100% of the cost for employees working in California, Florida and Massachusetts.

Reporting an Occupational Illness or Injury

When employees report an occupational illness or injury in a timely manner, EVAWI can investigate promptly, follow all applicable laws, and work with the employee to begin processing a workers’ compensation claim. This is important because workers’ compensation insurance, regardless of the specific provider, will have varying reporting mandates and specific procedures to follow to ensure coverage under an existing policy and to obtain all the benefits an employee might be entitled to.

In the event of an or work-related illness requiring medical intervention, the CEO (or a designee in the event of the CEO’s absence), shall be notified by telephone as soon as practically possible. If the employee is unable to make the notification due to injury or illness, every attempt will be made to have another responsible person do so at the time of the medical intervention or as soon as practically possible.

Within 24 hours of the event, an EVAWI Incident Report of /Injury form (Appendix K) shall be completed to report any event that caused an injury or resulted in medical attention – no matter how minor it might seem at the time. This form shall be completed by employees, or if an individual is incapacitated and unable to complete the form, their immediate supervisor will complete the form and submit it to the Chief Executive Officer (CEO) for further action.

Filing a Workers’ Compensation Claim in Washington

The CEO, and immediate supervisors, are responsible for ensuring that any injured employee understands that Washington State law requires the injured employee or care provider to file a Report of Accident in order to receive benefits. The employee can file a claim online, by phone at 1-877-561-3453, or at the provider’s office. The paperwork needed will depend on the type of injury or . Clearly filling out the accident report form and explaining the injury will reduce delays and help ensure that employees get all the benefits they are entitled to.

Read the information provided carefully, respond promptly, and keep copies of everything. Always make sure the claim number is included on all paperwork and have it available when calling the Department of Labor and Industries. For further information, refer to the Department of Labor and Industries.

Steps an Employee Needs to Take to File a Claim in Washington

Washington workers' compensation claims can be filed online, by phone or in person. The more information provided, the faster a claim can be processed. After seeking medical intervention, gather the following information:

• Location where the injury occurred. • Contact information for any witnesses to the injury. • Employer information. • information. • Names and birthdates of dependents. • If a doctor has been seen, the doctor's first and last name. • Hospital or clinic where treatment was received.

Steps EVAWI Needs to Take When an Employee is Injured

EVAWI must file a Washington State Department of Labor and Industries Employer Report of Accident form on line for an injured employee. By law, EVAWI MUST report to Labor and Industries, the death or in-patient hospitalization of any employee (within 8 hours) and any non-hospitalized amputation or loss of eye (within 24 hours) due to an on-the- injury by calling 1-800-423-7233.

Frequently Asked Questions Workers Have

Visit the Washington State Department of Labor & Industries website for answers to these common questions:

• How do I file a claim? • What is the deadline for filing a claim with L&I for an on-the-job injury? • I don't have online access. Can I file by phone? • What information goes on the accident report? • What L&I paperwork can I expect in the mail? • What paperwork can I expect to receive from my self-insured employer? • How long will it take to find out if my claim has been accepted? • Can I get help understanding the claim process? • Updating information: How do I let Labor and Industries, or my self-insured employer know if my address, doctor, or other information changes? • What if I live or move out of state?

Injured Out of State

A Washington state worker can file a claim in Washington even if the injury occurs out of state. Claims can be filed in both Washington and in the state or country in which the employee was injured, but any benefits received from another state will be credited against any benefits to which an employee may be eligible from the Washington State Department of Labor and Industries.

Visit the Washington State Department of Labor & Industries website for answers to these common questions:

• How do I know if I am a Washington worker? • What if I don't regularly work in a state my employer has a place of business? • What if I don't work either in a state where my employer has a place of business nor in the state I reside, or what if I work outside the United States?

Understanding Your Rights as an Injured Worker

Workers who are injured on the job and file a claim have the right to:

• Protection against discrimination for filing a claim.

• Protest Labor and Industries’ decisions.

• Change doctors.

• Take legal action against a "third-party" (someone not their employer) who may be responsible for the injury.

Visit the Washington State Department of Labor & Industries website for answers to these common questions:

• Can my employer fire me for filing a claim? • What if I think my injury was the fault of a third party? • May I change doctors or seek a second medical opinion after my claim is filed? • If the accident was my fault, are my medical bills covered? • If my claim is closed and my injury worsens, may I apply to reopen my claim? • What if I disagree with an L&I decision and want to protest? • What if I disagree with a decision made by my self-insured employer? • Can I get help understanding the claim process? • What if I live or move out of state?