Corporate Integrity

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Policy

 PIC requires its directors, officers, employees and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities within the agency.  As representatives of PIC, we must practice honesty and integrity in fulfilling our responsibilities and must comply with all state and federal laws and regulations including the prevention and detection of fraud, waste, and abuse.  Examples of state and federal regulations include but are not limited to Title VI of the Civil Rights Act, The Health Insurance Portability and Accountability Act (HIPAA), the Deficit Reduction Act (DRA), and the Federal False Claims Act.

Practice

  1. Reporting Responsibility
    1. It is the responsibility of all employees to report any action or suspected action taken within PIC that is illegal, unethical or violates any adopted policy of PIC.
    2. Anyone reporting a violation must act in good faith, without malice to the agency or any individual in the organization and have reasonable grounds for believing that the information shared in the report indicates that a violation has occurred.  A person who makes a report does not have to prove that a violation has occurred.  However, any report that the reporter has made maliciously, or any report that the reporter has good reason to believe is false, will be viewed as a serious disciplinary offense.
  1. No Retaliation
    1. No employee who in good faith reports a violation or who, in good faith, cooperates in the investigation of a violation shall suffer harassment, retaliation or adverse employment consequences.  
    2. Any individual within the agency who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment or volunteer status.  If you believe that an individual who has made a good faith report of a violation or who has, in good faith, cooperated in the investigation of a violation is suffering harassment, retaliation or adverse employment consequences, please contact the Compliance Officer.
  1. Reporting Violations
    1. PIC maintains an open-door policy and suggests employees share questions, concerns, or complaints with someone who can address them properly.  In most cases, an employee’s supervisor is in the best position to address an area of concern.  However, employees who are not comfortable speaking with their supervisor or are not satisfied with their supervisor’s response are encouraged to speak with the Deputy Director or anyone in management the employee is comfortable approaching.  
    2. Supervisors and managers are required to notify the Executive Director of every report of a violation.  The Executive Director has specific and exclusive responsibility to investigate all reported violations.  For suspected fraud, or when you are not satisfied or uncomfortable with following PIC’s open-door policy, individuals should contact the Executive Director directly.
  1. Compliance Officer
    1. The Executive Director will serve as PIC’s Compliance Officer.
    2. Responsibilities include; investigating all reported violations and for causing appropriate corrective action to be taken if warranted by the investigation.
    3. The Executive Committee of the board of directors is responsible for addressing all reported concerns or complaints of violations relating to corporate accounting practices, internal controls or audits.  Therefore, the Compliance Officer must immediately notify the Executive committee of any such concern or complaint.
    4. The PIC Compliance Officer has direct access to the board of directors and is required to report to the board of directors at least annually on compliance activity.