Chautauqua Patrons Insurance Company
Whistleblowing Policy
Summary
This policy governs both the reporting and investigation of allegations of suspected unlawful or improper activities and the protection of whistleblowers from retaliation. It describes the procedures for investigating suspected unlawful or improper activities and addressing complaints of retaliation against individuals making such reports.
Reporting and whistleblowing may involve, but is not limited to allegations of suspected unlawful or improper activities; unfair or unethical conduct; unsafe or dangerous activity; unlawful discrimination; harassment/sexual harassment; fraud; accounting irregularities; theft; or other wrongful conduct that may affect the safety, soundness, or reputation of CPIC.
Policy
The Chautauqua Patrons Insurance Company (CPIC) is committed to upholding the highest standards of ethics and integrity. CPIC has a responsibility for the stewardship of company resources and the support that enables it to pursue its mission. The company’s internal controls and operating procedures are intended to detect and prevent or deter unlawful or improper activities. However, intentional and unintentional violations of laws, regulations, policies and procedures may occur and may constitute unlawful or improper activities. CPIC has a responsibility to investigate and report to appropriate parties, allegations of suspected unlawful or improper activities, and to protect those employees who, in good faith, report these activities to the appropriate authority.
All employees, officers, board directors, agents, and stakeholders are encouraged to report any instance of suspected unlawful or improper conduct on the part of the Chautauqua Patrons Insurance Company or its personnel. Accordingly, a CPIC employee, agent, officer, or board director who comes forward in good faith with reports or concerns about suspected unlawful or improper activities shall not be subject to intimidation, harassment, discrimination or other retaliation, or in the case of employees, adverse employment consequences for making such a report. Any employee who believes that he/she is being retaliated against for making such a report should immediately bring it to the attention of the appropriate authority. It is the intention of Chautauqua Patrons Insurance Company to take whatever action deemed appropriate to prevent and correct activities that violate this policy.
Procedure
Filing a Report of Suspected Unlawful or Improper Activities
Any one or more persons or entities may – and should – report allegations of suspected unlawful or improper activities; unfair or unethical conduct; unsafe or dangerous activity; unlawful discrimination; harassment/sexual harassment; fraud; accounting irregularities; theft; or other wrongful conduct that may affect the safety, soundness, or reputation of CPIC. Knowledge or suspicion of such activity may originate from employees, officers, agents, board directors, external auditors, law enforcement, regulatory agencies, customers, vendors or other third parties.
Allegations of suspected unlawful or improper activities should be made in writing so as to assure a clear understanding of the issues raised; but may be made verbally.
If reporting verbally, a report by a CPIC employee of allegations of a suspected unlawful or improper activity should be made to the reporting employee’s immediate supervisor. However, when there is a potential conflict of interest or for other reasons, such reports may be made to any Vice President or the Executive Vice President/CEO. When the alleged unlawful or improper activities involve a Vice President, such reports should normally be made to the Executive Vice President/CEO. When the alleged improper activities involve the Executive Vice President/CEO, such reports should be made to the Chairman of the Board of Directors. All employees, officers, agents, board directors, vendors, consultants and stakeholders who receive such reports should immediately report them to the Executive Vice President/CEO or the Chairman of the Board of Directors, if appropriate. The Executive Vice President/CEO is designated to administer this Whistleblowing Policy.
The complainant may also report by using the link to the fillable electronic document, or printing the completed document and sending it to the appropriate Vice President, or Executive Vice President/CEO, or Chairman of the Board of Directors. Such reports should be factual and contain as much specific information as possible. Reports may be made anonymously if the complainant desires.
Protection from Retaliation
Any employee who believes he or she has been subjected to or affected by a retaliatory conduct for reporting suspected unlawful or improper activities, should report such conduct to the reporting employee’s immediate supervisor. However, when there is a potential conflict of interest or for other reason, such reports may be made to any Vice President or the Executive Vice President/CEO. When the alleged unlawful or improper activities involve a Vice President, such reports should be made to the Executive Vice President/CEO. When the alleged unlawful or improper activities involve the Executive Vice President/CEO, such reports should be made to the Chairman of the Board of Directors.
All employees who receive such reports should immediately report them to the Executive Vice President/CEO or the Chairman of the Board of Directors, if appropriate.
Investigation-General Allegation
The principal responsibility for conducting an investigation rests with the Executive Vice President/CEO. If the investigation involves the EVP/CEO, the responsibility rests with the Board of Directors and/or the Corporate Governance Committee. The EVP/CEO or Board of Directors/Corporate Governance Committee may request that the individual subject to the whistleblowing complaint present information or answer questions prior to deliberations or vote on the matter. All reports will be taken seriously and addressed promptly, discreetly and professionally. At the conclusion of an investigation, a determination will be made as to the appropriate corrective action, based on the factual findings of the investigation. Discussions and documentation regarding reports will be kept in confidence to the extent reasonable or permitted by policy or law. The Executive Vice President/CEO (and/or the Board of Directors/Corporate Governance Committee) is charged with the responsibility of preserving the confidentiality of reported information.
Investigation-With respect to any Accounting Allegations and any Other Allegations Directed Against Company Officers
- If the Board Corporate Governance Committee determines that management should investigate, the Corporate Governance Committee will notify Legal Counsel of that conclusion. Management shall thereafter promptly investigate, and the Legal Counsel shall report the results of the investigation to the Corporate Governance Committee. If management determines action is warranted after investigation, it shall provide status reports to the Corporate Governance Committee until such action has been completed. The Corporate Governance Committee may take over the investigation from management at any time, if it determines that management is not appropriately investigating, and may direct action other than that determined by management.
- If the Corporate Governance Committee investigates, upon conclusion of its investigation, the Corporate Governance Committee shall determine whether action is warranted. Management shall be advised in writing of any action directed by the Corporate Governance Committee and shall provide status reports to the Corporate Governance Committee until such action has been completed.
Board Communication
A summary of reports received under this policy containing the nature, status and action taken, will be communicated to the Corporate Governance Committee on a semi-annual basis or a more frequent basis when conditions warrant more timely action.
In addition to the complaint process set forth above, any employee who has information concerning alleged or suspected unlawful or improper activities, unfair or unethical conduct; unsafe or dangerous activity; unlawful discrimination; harassment/sexual harassment; fraud; accounting irregularities; theft; or other wrongful conduct that may affect the safety, soundness, or reputation of CPIC may contact the appropriate government agency.
Policy Distribution/Conveyance
This policy shall be distributed and/or made available to all employees, officers, board directors, agents and stakeholders of Chautauqua Patrons Insurance Company via access to the Company’s private or public website.
Policy Date: 02.06.2019
To make a complaint please open the following link: Ethics Complaint Form