Policy Statement

Parkinson Canada is committed to dealing responsibly, openly and professionally with any genuine concern that employees, volunteers, directors and directly contracted persons employed with Parkinson Canada (collectively, “employees”) may have about any practice, procedure or policy carried out by Parkinson Canada. Parkinson Canada encourages employees to raise their concerns about any incidents related to complaints of organizational wrongdoing at the earliest possible stage. Every effort will be made to resolve the situation promptly. If this is not possible, Parkinson Canada will take further action to fully investigate and then take appropriate action.

Responsibility

Each Director, Volunteer, and Employee of Parkinson Canada has an obligation to internally report in accordance with this Whistleblower Policy within 90 days of discovering the alleged violation. All employees, volunteers and directors are required to be familiar with the terms of this policy. Individual managers are responsible for ensuring that this policy is communicated and applied within their own area. Questions regarding this policy should be directed to a Parkinson Canada Manager or the CEO.

Policy Details

Authority

All concerns will be forwarded to the Parkinson Canada Board Chair in accordance with the procedures in this policy. The Parkinson Canada Board Chair shall be responsible for ensuring all concerns are discussed, investigated as necessary, and make appropriate recommendations to the Parkinson Canada Board of Directors, with respect to all reported concerns. The Parkinson Canada Board Chair may consult the Officers of the Board and the CEO, as appropriate.

Reporting Concerns

This Whistleblower Policy is intended to encourage and enable employees to raise concerns that may include (but are not necessarily limited to) a suspected violation of: ethics, the law, a suspected violation of any regulation governing the operations, or a fraud within the organization for investigation and appropriate action. Employees should share their concerns with someone who can address them properly and promptly. In most cases their supervisor is in the best position to address a concern. However, if the employee is not comfortable speaking with the supervisor about the concern, the employee is encouraged to speak with staff in Human Resources or anyone in management with whom they are comfortable in approaching. Supervisors and managers are required to report concerns to the Parkinson Canada CEO and Board Chair.

Employees are notified of this policy on the Parkinson Canada web-site and through employee orientation and training. Directors and other volunteers should submit concerns in writing directly to the Parkinson Canada Board Chair. The Parkinson Canada Board Chair may be contacted at: parkinsoncanadachair@parkinson.ca.

Handling of Reported Violations

The Parkinson Canada Board Chair shall address all reported concerns. The Chair shall notify the Parkinson Canada Board Officers of any such report within three business days. The Chair will notify the sender and acknowledge receipt of the concern within five business days, if possible. It may not be possible to acknowledge receipt of anonymously submitted concerns. The Chair will ensure discussion and investigation of all reported concerns. Upon disclosure of a concern an interview will be arranged with the individual by a designated Parkinson Canada representative, in confidence, to discuss the concern raised as soon as possible.

The Chair will ensure timely investigation and resolution of all reported concerns. Upon disclosure of a concern an interview will be arranged with the individual by a designated Parkinson Canada representative, in confidence, to discuss the concern raised as soon as possible.

If the concern raised is found to be valid one or more of the following steps may be taken:

  1. Refer the matter to an executive staff member to carry out an internal investigation;
  2. Refer to a technical expert;
  3. Refer the matter to the Parkinson Canada Board of Directors. An investigation will be done in consultation with the most appropriate individuals (which may include the CEO, other Board officers, and the Parkinson Canada Board), and appropriate action will be recommended to the Parkinson Canada Board of Directors, if warranted by the investigation;
  4. The Chair has the authority to retain outside legal counsel, accountants, private investigators, or any other resource deemed necessary to conduct a full and complete investigation of the allegations; and/or
  5. Refer the matter to the police.

Unless exceptional circumstances make it inappropriate, the individual will be told what action Parkinson Canada has decided to take and the individual must treat such information in the strictest confidence.

In addition, action taken must include a conclusion and/or follow-up with the individual for complete closure of the concern. If dissatisfied with the way the disclosure has been dealt with, concerns in writing may be raised, on a confidential basis with the Parkinson Canada Board of Directors.

Acting in Good Faith

Any employee reporting a concern must act in good faith and have reasonable grounds for believing the information reported indicates a violation of the law, or constitutes an inappropriate accounting or financial practice.

If an allegation is made in good faith that is not confirmed by subsequent investigation, no action will be taken against the individual. The act of making allegations that prove to be unsubstantiated, and that prove to have been vexatious or made maliciously, recklessly, or with the foreknowledge that the allegations are false, may result in disciplinary actions.

Confidentiality

Reports on concerns, and investigations relating to the concerns, shall be kept confidential to the extent practical, consistent with the need to conduct an adequate investigation.

Provided that concerns have been raised in good faith and have complied in full with this policy, steps set out above the following will apply:

  1. 1. So far as possible the identity of the individual will not be disclosed at any time by Parkinson Canada unless necessary for the purposes of its investigation, to obtain legal advice or to comply with a legal or regulatory obligation. Where this is the case the individual will be advised.
  2. While every effort will be taken to ensure identity is not disclosed it may become necessary to identify the individual or become possible for third parties to deduce identity. For this reason, no guarantee of anonymity can be given.
  3. So far as possible any supporting evidence relating to the individual’s concerns will be kept secure at all times.
  4. No individual who, in good faith, reports a concern shall be subject to retaliation or, in the case of an employee, adverse employment consequences related to whistleblower concerns.
  5. Disclosure of reports of concerns to individuals not involved in the investigation may result in disciplinary actions.

Statement of Understanding

In order to ensure that all employees and board members are aware of the policy, each will be asked to sign and date a Statement of Understanding confirming that the policy has been read and understood.