The Whistleblower Policy was created to provide direction to Ducks Unlimited Canada’s stakeholders in the communication of concerns regarding questionable financial or operational matters. Whistleblower incidents can be reported to our Manager, Risk & Compliance, in confidence, using the online Whistleblower Form, after reviewing the Whistleblower Policy.
A “whistleblower incident” is when any stakeholder has reported a financial or operational incident of concern. The Whistleblower Policy was created to provide direction to our stakeholders in the communication of concerns regarding questionable financial or operational matters.
Examples of whistleblower incidents may include, but are not limited to, the following:
- Misrepresenting program budgets
- “Side deals” or “under the table” dealings with contractors for personal benefit
- Receiving personal kickbacks or significant gifts (over $100) from contractors or vendors which could create bias in the tendering process
We believe in the value of responsible, sound governance practices and supports that belief through action and policy. Along with other governance innovations, the Whistleblower Policy will ensure that we continue to demonstrate due diligence in its operations.
When a whistleblower incident is sent via the internet, the electronic form is simultaneously sent to the President of the Board of Ducks Unlimited Canada, the Chair of the Finance and Risk Committee andManager, Risk & Compliance.
Once received, the submission is assessed by theManager, Risk & Compliance and a recommendation on investigation protocol is sent to our President and the Chair of the Finance and Risk Committee. Consensus is reached and then the appropriate action and investigation commences, involving various levels of management and the Board dependent on the severity of the incident reported.
A report is prepared for the Finance and Risk Committee of our Board of Directors.
All whistleblower incidents shall be communicated and resolved using the Company’s prescribed procedures. Each whistleblower incident will be treated with confidentiality and due care. It is our policy that the whistleblower will not be negatively affected in any way. We recognize the significance of this policy, and as such will not protect whistleblowers who undermine the policy by reporting intentionally false accusations.
A Whistleblower Form is used to communicate appropriate whistleblower incidents. The whistleblower’s identity will be protected, and they can choose to remain anonymous. If a name is provided, the Whistleblower will be contacted within 10 days and will be notified of planned follow-up action. Please read the complete Whistleblower Policy before submitting.
Following an investigation, each whistleblower incident will be rated according to policy to determine their validity, significance, ability to be proven. Appropriate action will be taken and all reported incidents will be documented and logged. The results will be communicated to the Whistleblower, if a name was provided.Go to the Whistleblower Policy and Form
Questions relating to this Whistleblower Policy should be directed to:
Neil Richard, CPA, CA
Manager, Risk & Compliance