Background:
Under the provisions of the Sarbanes Oxley Act of 2002, certain organizations must adopt a policy whereby there is a mechanism for an employee to report illegal or fraudulent activities to the highest level of the organization, without fear of reprisal or acts of intimidation. Although not subject to the requirements of Sarbanes-Oxley, because Gateway-Longview, Inc.(hereinafter referred to as the “Agency”), wishes to operate in a legal, ethical, and prudent manner, both in fact and appearance, the Agency therefore adopts this Policy on Reporting Illegal or Fraudulent Behavior as a matter of management policy. Effective immediately, the procedures outlined below are hereby adopted and shall be followed with respect to reporting illegal or fraudulent activities. As a provision of this policy, the Agency shall keep the identity of the reporting employee confidential. Should it become necessary, during the course of legal process, or otherwise, to reveal the name of the employee, the employee will not be subjected to reprisal in any form, for reporting the illegal fraudulent activity.
Policy and Procedure;
Any Agency employee may report illegal of fraudulent activity to the Board Chair, Executive Director, Treasurer, or any other officer or Director of the Agency. If the employee wishes to report such activity, the employee may either write a detailed, confidential letter, or submit a detailed report on the observed activity, in an envelope marked “Confidential.” The letter or report may be placed in interoffice mail, US mail, or hand delivered. The letter or report must contain specific information as to the time, date, and nature of the reported activity. Should the employee desire a response to the letter or report, the letter or report needs to be signed and dated. Any report to be sent to the Chairman or Treasurer during the current year through June 30, 2006, may be mailed to:
Board of Directors Chairman
Mr. Joseph Kreuz
AP Professionals
5110 Main St.
Walker Center
Williamsville, NY 14221
Board of Directors Treasurer
Mr. Patrick Reilly
John W. Danforth Co.
300 Colvin Woods Parkway
Tonawanda NY 14150
The Agency officer to whom the report is addressed shall evaluate the report, and if the report is signed, shall take appropriate action including, where warranted, responding to the individual submitting the report. If the person to whom the report is addressed leaves office (e.g., the Chair or Treasurer rotates off the Board in the time frame allotted for a response), the successor to the officer shall issue the response.
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