Purpose Statement:

POLICY

The Space Coast Health Foundation requires Board of Directors, officers and employees to observe high standards of both business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the Foundation, said Board of Directors, officers and employees must practice honesty and integrity in fulfilling responsibilities and complying with applicable laws and regulations. “Wrongful Conduct”, as defined in this Policy, is prohibited.

This Policy is intended to reflect the requirements of Sections 448.101 through

448.105 of the Florida Statutes (2010), as amended.

REPORTING RESPONSIBILITY

It is the responsibility of all Board of Directors, officers and employees to comply and report to the appropriate representative of the Foundation any Wrongful Conduct violations or suspected violations in accordance with the provisions of this Policy.

“Wrongful Conduct” is any activity in violation of any state, federal or local law or regulation or any Foundation policy undertaken by a Board of Directors, officer or employee in the performance of such individual’s official duties, whether or not such activity is within the scope of his or her intended responsibilities on behalf of the Foundation. This includes, but is not limited to, corruption, malfeasance, bribery, theft, fraud, deliberate error, coercion, conversion, malicious prosecution, failure to comply with policies of the Foundation, harassment, or deliberate misuse of the Foundation’s property and facilities.

NO RETALIATION

No Director, officer or employee who reports Wrongful Conduct to the foundation in good faith in accordance with this Policy shall suffer any retaliatory personnel action or adverse employment consequence as a result of such report. Any person who retaliates against a person who has reported Wrongful Conduct in good faith is subject to discipline up to and including termination of employment. This policy is intended to encourage and enable employees and others to report Wrongful Conduct to the Foundation, prior to seeking resolution outside the Foundation, when such person has a reasonable belief that Wrongful Conduct has occurred or is ongoing.

Directors, officers and employees are also protected against retaliatory personnel actions as a result of such person disclosing, or threatening to disclose, in writing, under oath, to any governmental agency, an activity, policy or practice of the Foundation that is in violation of a law, rule or regulation, provided, however, that such person has first brought the activity, policy or practice to the attention of the Foundation in writing (see Reporting Violations) and the Foundation has had a reasonable opportunity to correct the activity, policy or practice.

Directors, officers and employees are also protected against retaliatory personnel actions as a result of such person providing information to, or otherwise cooperating or participating in an investigation, hearing or inquiry into an allegation of Wrongful Conduct conducted by a regulatory authority, law enforcement agency, or any person with supervisory authority over an employee. Any Board of Director, officer or employee who files, testifies, or otherwise assists in a proceeding relating to alleged Wrongful Conduct is also protected against retaliation.

Similarly, no Director, officer or employee shall suffer retaliatory personnel action because such person objected to or refused to participate in, any activity, policy or practice of the Foundation which is in violation of a law, rule or regulation.

REPORTING VIOLATION

Any Directors, employee or officer may address alleged violations either in writing or in person to the President/CEO of the Foundation or the Board Chair of the Foundation or any other Board Member if it concerns the President/CEO or Chair.

Telephone communications should be directed to the numbers listed below, but should not be used in lieu of any written communication:

Written communication to such persons should be sent to the following addresses:

Johnette Gindling President/CEO
or
Linda Dale, Board Chair
Space Coast Health Foundation 1100 Rockledge Blvd., Suite 100
Rockledge, FL 32955

The Foundation suggests that employees share their questions, concerns or complaints first with a supervisor in order to seek resolution. However, if they are not comfortable doing so, they should immediately initiate the above reporting protocol.

ACCOUNTING AND AUDIT MATTERS

The Board of Directors shall address all reported concerns or complaints regarding Foundation accounting practices, internal controls or auditing. All allegations of Wrongful Conduct will be thoroughly investigated and corrective action taken as needed.

ACTING IN GOOD FAITH

Anyone filing a complaint alleging suspected Wrongful Conduct must be acting in good faith and have reasonable cause for believing the information disclosed constitutes Wrongful Conduct. An employee who brings allegations that prove to be unsubstantiated, and which prove to have been made maliciously, or without a reasonable basis for believing the information disclosed constitutes. Wrongful Conduct may be subject to discipline, up to and including termination of employment.

CONFIDENTIALITY

Reports of violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Such reports will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

HANDLING OF REPORTED WRONGFUL CONDUCT

The President/CEO or Board Chair will notify the sender and acknowledge receipt of the allegation of Wrongful Conduct within 5 business days, unless received anonymously. All reports will be promptly investigated and appropriate corrective action will be taken, if warranted by the investigation, up to and including disciplinary action, termination of board membership or employment, seeking restitution, removal from office, or criminal prosecution