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I. The general purpose of this policy is to protect any person who makes a good faith disclosure of suspected wrongful conduct or violations of the IDP/ Innovation Inishowen Skillnet Code of Conduct. Innovation Inishowen Skillnet prohibits any discrimination, retaliation or harassment against anyone making such a report, or participating in an investigation. Innovation Inishowen Skillnet encourages an atmosphere that allows individuals to raise concerns, and/or to meet their obligations to disclose violations of law and serious breaches of conduct covered by Innovation Inishowen Skillnet policies and be free of discrimination, retaliation, threats or harassment.
II. The Management are responsible for the implementation and administration of this policy.
III. The IDP Board of Management as Promoters are responsible for the stewardship of
Innovation Inishowen Skillnet its delivery and resources up to and including the public and private support that enables us to fulfil our mission.
Directors, officers and employees are required to observe high standards of business and personal ethics and practice honesty and integrity in fulfilling duties and responsibilities. Innovation IDP/Inishowen Skillnet are committed to compliance with the laws and regulations to which it is subject to and in disseminating policies and procedures to interpret and apply these laws and regulations.
Laws, regulations, policies and procedures strengthen and promote sound practices and ethical treatment of staff, and service users we serve. IDP/Innovation Inishowen Skillnet’s internal controls and operating procedures have been developed to detect and to prevent or deter improper activities; however, even the best of systems of control cannot ensure absolute safeguards against irregularities or improper activity. IDP and Innovation Inishowen Skillnet has a responsibility to investigate and report to appropriate parties allegations of suspected improper activities and the actions taken by Innovation Inishowen Skillnet. In all instances, IDP on behalf of Innovation Inishowen Skillnet and in co-operation with Skillnet Ireland retains the prerogative to determine when circumstances warrant an investigation (in conformity with this policy and applicable laws and regulations) and the appropriate investigative process to be employed.
IDP on behalf of Innovation Inishowen Skillnet has adopted this policy to:
a)Cause violations or suspected violations to be disclosed before they can disrupt the operations of IDP/Innovation Inishowen Skillnet , and or Skillnet Ireland.
b)Promote a climate of accountability with respect to IDP/Innovation Inishowen Skillnet resources, including its employees, and
c)To ensure that no one should feel at a disadvantage in raising legitimate concerns. The whistleblowing procedure is intended to be used for serious and sensitive issues such as serious concerns relating to financial reporting, or unethical or illegal conduct.
Employee-related concerns should continue to be reported through the relevant Manager; Service User grievances should continue to be reported according to the Complaints Procedure.
IV. Every director, officer and employee is responsible to comply with the
Policies and Procedures of the IDP and Innovation Inishowen Skillnetand to report violations or suspected violations in accordance with this Whistleblower Policy.
The report should be made immediately at the time they become aware of the violation or suspected violation. A violation may consist of any of the following:
a) A violation of a law or regulation
b) Violations of internal accounting controls or actions that may lead to incorrect or fraudulent financial reporting
c) The mismanagement or gross misuse of resources entrusted to IDP and/or Innovation Inishowen Skillnet
d) Any violation of the IDP/Innovation Inishowen Skillnet Policies and Procedures of IDP and Innovation Inishowen Skillnet or actions that otherwise amount to serious improper conduct
e) Any attempt to conceal a potential violation or evidence of a potential violation
f) Any retaliation for any report, complaint, allegation, or other disclosure made pursuant to this policy.
IV. A whistleblower is a person or entity disclosing a violation or suspected violation. Whistleblowers may be employees, applicants for employment, clients, vendors, contractors or the general public.
It is important that a whistleblower feels safe and protected from retaliation when a good faith report of known or suspected violations of the Policies and Procedures of IDP and Innovation Inishowen Skillnet is made.
V. Whistleblower’s are “reporting parties”; they are not to act on their own in conducting investigative activities, nor do they have a right to participate in any investigative activities other than as requested by investigators. Likewise, whistleblowers do not determine the appropriate corrective or remedial action that may need to be taken. Whistleblowers should refrain from attempting to obtain evidence for which they do not have a right of access. Such improper access may itself be considered a violation of the Code of Ethics. Whistleblowers have a responsibility to be candid when reporting a suspected violation of the Policies and Procedures of IDP and Innovation Inishowen Skillnet and shall set forth all known information regarding any reported allegations. Persons making a report of suspected violations should be prepared to be interviewed by IDP investigators.
VI. Directors, officers or employees who in good faith report a violation or impropriety shall not suffer harassment or retaliation. Employees who retaliate against someone who has reported a violation in good faith are subject to discipline up to and including termination of employment. The intent of this Whistleblower Policy is to encourage and enable employees and others to raise serious concerns within the organisation prior to seeking resolution outside the organisation.
VII. IDP/Innovation Inishowen Skillnet is prohibited from knowingly discriminating or retaliating against an employee because the employee has in good faith:
a) Reported orally or in writing, criminal activity by any person.
b) Reported orally or in writing, any activity the employee in good faith believed to be criminal or caused criminal charges to be brought against any person
c) Cooperated with an Garda Siochana
d) Brought a civil proceeding against an employer
e) Testified at a civil proceeding or criminal trial, whether or not under subpoena. A whistleblower’s right to protection from retaliation does not extend immunity for any complicity in the matters that are the subject of the allegations or ensuing investigation.
Likewise, a whistleblower’s right to protection does not exempt an employee from the usual components of an employer-employee relationship, including but not limited to coaching and corrective or disciplinary action.
VIII. Anyone filing a complaint concerning a violation or suspected violation of the Policies and Procedures of the IDP and Innovation Inishowen Skillnet must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the Code of Ethics. Good faith means that a person has a reasonably held belief that the disclosure made is true and has not been made out of malice, jealousy, for personal gain or for any ulterior motive. The intentional filing of a false report, whether orally or written, is itself considered a violation of the Policies and Procedures of IDP and Innovation Inishowen Skillnet which IDP/ Innovation Inishowen Skillnet has the right to act upon.
IX. Employees are encouraged to share their questions, concerns, suggestions or complaints with someone who can address them properly. This person will usually be the direct supervisor or Promotor or Skillnet Manager, or anyone in management whom you are comfortable in approaching. If the employee’s supervisor is believed to be involved in the alleged violation, the employee should go to the IDP Chairperson of the Promoting Organisation . For suspected fraud or serious violations of the Code of Ethics, or when you are not satisfied or uncomfortable with these steps, individuals should contact the IDP Chairperson directly. Supervisors and managers who receive a report alleging suspected violations of the Policies and Procedures of IDP and Innovation Inishowen Skillnet shall ensure that the matter is promptly reported to their supervisor and are required to report it to the Innovation Inishowen Skillnet Manager, who has specific responsibility to investigate reported violations. Oral reports should normally be documented by the supervisor or manager with a written transcription of the oral report.
Written communications should be clearly marked “personal and confidential”.
Reports or allegations of violations of the Policies and Procedures of IDP and Innovation Inishowen Skillnet are encouraged to be made by completing the Confidential Disclosure Report Form in order to assure a clear understanding of the issues raised, but may be made orally. This can either be completed by the person making the report or by the manager receiving the report.
The report should be factual rather than speculative or attempting to make conclusions; it should contain as much specific information as possible to allow for proper assessment, , extent and urgency of preliminary investigative procedures. Anonymous whistleblowers must provide sufficient corroborating evidence to prompt an investigation.
An investigation of unspecified wrongdoing or broad allegations may not be undertaken unless there is verifiable evidence to support the allegation. Because investigators are unable to interview an anonymous whistleblower, it may be more difficult to evaluate the credibility of the allegations and therefore, less likely to prompt initiation of an investigation.
X. The Innovation Inishowen Skillnet Manager shall report to the IDP Chairperson any allegations of suspected violations of the Policies and Procedures of the IDP and Innovation Inishowen Skillnet– whether received as a disclosure from an employee, reported by their subordinates in the ordinary course of performing their duties, or discovered in the course of performing their own duties – when any of the following conditions are met: a) The matter is a result of a significant internal control or policy deficiency that is likely to exist across IDP/ Innovation Inishowen Skillnet; b) The matter is likely to receive media or other public attention; c) The matter involves the misuse of IDP/ Innovation Inishowen Skillnet resources or creates exposure to a liability in potentially significant amounts; d) The matter involves allegations or events that have a significant possibility of being the result of a criminal act (e.g., disappearance of cash); e) The matter involves a significant threat to the safety and health of employees and/or the public; or f) The matter is determined to be significant or sensitive for other reasons.
XI. The Innovation Inishowen Skillnet Manager is responsible for leading the investigation of and resolving all reported complaints and allegations concerning violations of the Policies and Procedures of IDP and Innovation Inishowen Skillnet and, at his/her discretion, shall advise the Promotor and the IDP Chairperson and/or the Audit Committee.
XII. A report of all substantial disclosures and any subsequent actions taken will be made to the Board. Where the disclosure relates to an issue or matter within its purview, it will be a detailed report; in all other cases, it will be in summary. A person alleging a violation who is not satisfied with the response concerning the outcome of the investigation or who has not received a response in a reasonable time period may contact the Innovation Inishowen Skillnet Manager and also send a copy in writing to the Promotor and the IDP Chairperson. The review committee of the Board shall then make a preliminary investigation of the facts disclosed.
XIII. Confidentiality Violations or suspected violations may be submitted on a confidential basis by the person making the complaint or may be submitted anonymously. To the extent possible within the limitations of law and policy and the need to conduct a competent investigation, confidentiality of whistleblowers will be maintained. Whistleblowers should be cautioned that their identity may become known for reasons outside of the control of the investigators or Innovation Inishowen Skillnet Manager, such as occasions where certain violations must, by law, be reported to outside agencies. Similarly, the identity of the subject(s) of the investigation will be maintained in confidence with the same limitations.
An example of outside agencies would be that if an investigation concludes that a crime has probably been committed, the results of the investigation shall be reported to An Garda Siochana. Should the whistleblower self-disclose his/her own identity, IDP/ Innovation Inishowen Skillnet will no longer be obligated to maintain such confidentiality.
XIV. The Innovation Inishowen Skillnet Manager will notify the sender and acknowledge receipt of the reported violation or suspected violation within five (5) business days, except that if submitted anonymously, it will not be possible to acknowledge receipt. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. Deciding to conduct an investigation is not an accusation; it is to be treated as a neutral, fact-finding process. The outcome of an investigation may or may not support an allegation that an improper act was committed. The amount of contact between the person reporting the alleged violation and the person(s) investigating the concern will depend on the nature of the issue and the clarity of the information provided. Subject to any applicable legal constraints or special circumstances, the person reporting the alleged violation and the person(s) being investigated will receive information about the outcome of investigations.
XV. Employees who are asked to provide information or otherwise participate in an investigation have a duty to fully cooperate with IDP/ Innovation Inishowen Skillnet’s -authorised investigators. Participants should not discuss or disclose the investigation with anyone not connected to the investigation. In no case should the participant discuss with the person(s) being investigated the nature of evidence requested or provided or testimony given to investigators unless agreed to by the investigator. Requests for confidentiality by participants will be honoured to the extent possible within the legitimate needs of law and the investigation. Participants are entitled to protection from retaliation for having participated in an investigation. A subject is a person who is the focus of investigative fact findings either because an allegation has been made or evidence has been gathered during the course of an investigation. The identity of a subject should be maintained as confidential to the extent possible given the legitimate needs of law and the investigation and as outlined in the Confidentiality Section. Subjects should normally be informed of the allegations when a formal investigation is initiated, and should have opportunities for input during the investigation at the investigators’ sole discretion. Subjects have a duty to cooperate with investigators to the extent that cooperation will not compromise self-incrimination protections under law. Subjects have a right to consult with person(s) of their choice; this may involve representation, including legal representation. Subjects may at any time retain their own counsel to represent them with regard to the investigation. Subjects are responsible not to interfere with an investigation. Evidence shall not be withheld, destroyed or tampered with, and witnesses shall not be coached, influenced, intimidated, or retaliated against. Subjects should be given the opportunity to respond to material points of evidence contained in an investigation report unless there are compelling reasons to the contrary. An allegation of wrongdoing against a subject shall not be considered sustained unless, at a minimum, a preponderance of the evidence supports the allegation. Subjects have a right to be informed of the results of the investigation.
XVI. Investigators are those persons authorised by IDP/ Innovation Inishowen Skillnet to conduct fact finding and analysis related to allegations of violations. All investigators shall be independent and unbiased. Investigators have a duty of objectivity, fairness, thoroughness, ethical behaviour, and observance of legal and professional standards. Investigations should be launched only after preliminary consideration substantiates that the allegation, if true, constitutes an improper activity and either the allegation is accompanied by specific enough information to be investigated, or the allegation has or directly points to corroborating evidence that can be pursued.
XVII. The IDP Audit Committee or the Board of Directors can modify and update this policy at any time without notice. Modification may be necessary, among other reasons, to maintain compliance with regulations and/or to accommodate organisational changes within IDP/ Innovation Inishowen Skillnet.
XVIII. Mail: If making contact via mail, be sure to mark “personal and confidential” in large letters on the front of the envelope. Address the envelope to the Innovation Inishowen Skillnet Manager at the administration office. Email: If making contact via email, send an email to the Innovation Inishowen Skillnet Manager. Please note that for privacy and security reasons, client names should not be referenced in emails. You should receive an email back stating that your original email has been received. If you do not receive such an email, it may mean that your email might not have been delivered due to computer filtering activities, and another mode of contact, if this happens please contact us directly by phone or post.