The Food and Drug Administration Alumni Association (the "Association") is committed to maintaining a work environment where directors and officers are free to raise good faith concerns regarding potential wrongdoing, including (but not limited to) reporting suspected violations of law and identifying potential violations of the Association's policies. This policy governs the reporting and investigation of allegations of suspected wrongdoing, as well as the protection of whistleblowers from retaliation.
All directors and officers are required to comply with this policy (and the other polices of the Association) and to report violations and suspected violations of wrongdoing in accordance with this policy.
The Association takes seriously its responsibility to investigate reports of possible wrongdoing and to protect any director or officer who in good faith makes any such report to the Association or to a law enforcement agency.
The Association expressly prohibits any form of retaliation, including (but not limited to) harassment or intimidation, against any director or officer who reports in good faith a concern about possible wrongdoing and/or cooperates in any investigation thereof.
Any director or officer who engages in retaliation will be subject to discipline, up to and including removal from office. Malicious and untrue allegations of wrongdoing may result in disciplinary action, up to and including removal from office.
Any director or officer may report any good faith concern or suspicion about possible wrongdoing.
Although reports may be made anonymously, the Association encourages reporting individuals to identify themselves since anonymity may impair the Association's ability to investigate the concerns effectively. Every effort will be made to protect the reporting individual's identity.
Although reports may be made orally, the Association encourages written reports since these will create a record of the report and reduce the chance of a report being misunderstood. Reports should be factual and contain as much specific, relevant information as possible.
Reports of concerns or suspicions about possible wrongdoing should be made to the Chairperson of the Board of Directors. If the Chairperson of the Board of Directors is the person, or one of the persons, suspected of wrongdoing, or if making a report to that person is otherwise impractical or inappropriate under the circumstances, then the report may instead be made to any director or officer of the Association.
The action taken by the Association in response to a report of wrongdoing will depend on the nature of the concern expressed in the report and may include a referral of the report to a law enforcement agency. Initial inquiries may be made by the Association to determine whether an investigation is appropriate and, if so, the manner of the investigation.
The outcome of any investigation of a report of possible wrongdoing, and any other actions taken in response to a report, shall be reported in writing to the Chairperson of the Board of Directors.
These procedures for reporting concerns or suspicions about possible wrongdoing also apply to complaints of retaliation for having made such a report.
Approved by the FDAAA Board of Directors: October 15, 2009