1.9 Non-Retaliation and Non-Retribution for Reporting Policy

  • PURPOSE:

    LHCC understands that employees may not report concerns if they feel that they will be subject to retaliation or retribution or harassment for reporting the concern. To reassure employees who wish to report concerns through the Compliance Department, this non-retaliation/non-retribution policy has been established.

    POLICY:

    Supervisors, office managers, or employees are not permitted to engage in retaliation, retribution or any form of harassment directed against an employee who reports a Compliance concern. Anyone who is involved in any act of retaliation or retribution against an employee that has reported suspected misconduct in good faith will be subject to disciplinary action.

    PROCEDURE:

    • Employees have the responsibility to report, in good faith, concerns about actual or potential wrongdoing.
    • LHCC is committed to a policy that encourages timely disclosure of such concerns and prohibits any action directed against an employee, manager or staff member for making a good faith report of a concern.
    • Any manager, supervisor or employee who engages in retribution, retaliation or harassment against a reporting employee is subject to discipline up to and including dismissal on first offense.
    • All instances of retaliation, retribution or harassment against reporting employees will be brought to the attention of the Compliance Officer who will, in conjunction with the legal department, CEO and President, investigate and determine the appropriate discipline, if any.
    • If any employee reports a concern regarding his or her own inappropriate or inadequate actions, reporting those concerns does not exempt him or her from the consequences of those actions.
    • Prompt and forthright disclosure of an error by an employee, even if the error constitutes inappropriate or inadequate performance, will be considered a positive constructive action by the employee.

    Revised 11/2012

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