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Whistleblower Policy

Approved by the Board of Directors March 2014

NPMA is committed to fostering a workplace conducive to open communication regarding the organization's business practices and to protecting employees from unlawful retaliation and discrimination for having properly disclosed or reported possible illegal or unethical conduct. In an effort to further this commitment, this policy: (i) establishes guidance for the types of conduct to be reported; (ii) procedures for reporting concerns with such serious and sensitive issues; and (iii) makes clear the Association's intention to discipline, up to and including termination of employment, any person determined to have engaged in retaliatory behavior.

Questionable Conduct to be Reported
If an employee suspects another employee, director, officer, or NPMA representative has engaged in questionable conduct involving financial improprieties, misuse of the Association’s assets, or other fraudulent, dishonest, unethical, or illegal conduct detrimental to the interests of the Association, employees should report it. This misconduct may include outright theft (of equipment or cash), fraudulent expense reports, misstatements of any accounts to any manager or to the Association’s auditors, and of course, unlawful activities.

Reporting Procedure
If an employee suspects that an employee, director, officer or other NPMA representative has engaged in conduct described above, an employee may report it either confidentially or anonymously - and in either case the employee will be protected from retaliation for making such a report in good faith. An employee can make a confidential report to any of the following at any time: (1) Senior Management, (2) Executive Vice President, (3) President, or if none of those channels is productive or is not feasible, an employee can talk with the (4) Association’s Legal Counsel. NPMA will promptly conduct an investigation into the matter reported, keeping the identity of the reporting employee confidential at all times to the extent permitted by the legitimate needs of the investigation and by law, unless the employees decides otherwise. The employee will be informed of the results of the investigation.

If the employee wishes to submit an anonymous report, the employee may do so by U.S. Mail addressed to any of the individuals designated above. The envelope should have the statement “personal and confidential” clearly written on the front. If an employee makes a report anonymously, it will not be possible to provide that individual with the results of any investigation or to follow up with the employee for additional information that may be necessary to proceed. However, the report will be carefully reviewed, and if at all possible, investigated nonetheless.

Reporting Retaliation in Violation of this Policy
Retaliation against any employee that files a report or voices a concern under this policy is strictly prohibited. Retaliation includes adverse actions with respect to employment such as demotions, wage or hour reductions, denial of raise or benefits if otherwise eligible, and termination of employment. If, having made a report of suspicious conduct in good faith, an employee subsequently believes that he or she has been subjected to retaliation by any NPMA employee, director, officer or other representative, the employee should immediately report it to the Executive Vice President, member of the Senior Management Team, or if appropriate, the association’s legal counsel.

Reports of retaliation will be investigated promptly in a manner intended to protect confidentiality, consistent with a full and fair investigation. The party conducting the investigation will notify the employee of the results of the investigation. Any employee who engages in such retaliation will be subject to discipline up to and including termination.

Employees who knowingly file misleading or false reports, or without a reasonable belief as to truth or accuracy, will not be protected by this policy and may be subject to discipline, including termination of employment.