CRC Recovery Foundation, Inc.

Whistleblower Policy: Reporting Suspected Violations of Law and Policy

The CRC Recovery Foundation, Inc. (“CRC”), including its subsidiary, Living Skills in the Schools (“LSIS”), requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the CRC, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

1. Reporting Responsibility

It is the responsibility of all directors, officers, and employees to report violations or suspected violations in accordance with this Whistleblower Policy.

1. No Retaliation

No director, officer or employee who in good faith reports a violation shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the CRC prior to seeking resolution outside the CRC.

III.       Reporting Violations

The CRC’s open door policy suggests that employees share their questions, concerns, suggestions, 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, if you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with the Chief Executive Officer of Living Skills in the Schools and officers and/or directors are encouraged to speak with the President of the CRC Board of Directors or anyone on the CRC Board of Directors whom you are comfortable in approaching.  Employees are required to report suspected violations to the Chief Executive Officer of Living Skills in the Schools except that the Chief Executive Officer of Living Skills in the Schools is required to report suspected violations to the President of the CRC Board of Directors (“President”) (unless the President is the subject of the complaint, in which case, suspected violations should be reported to the Vice President of the CRC Board of Directors), both of whom have specific and exclusive responsibility to investigate all reported violations.  For suspected fraud, or when you are not satisfied or comfortable with following the CRC’s open door policy, employees should contact the Chief Executive Officer of the Living Skills in the School except that the Chief Executive Officer of Living Skills in the Schools should contact the President of the CRC Board of Directors (unless the President is the subject of the complaint, in which case, the Vice President of the CRC Board of Directors should be contacted). When this reporting policy is inappropriate for a particular situation, all of the above steps may be skipped and the President or the Vice President of the CRC Board of Directors can be contacted directly by any employee, officer or director.  The contact information for the President of the CRC Board of Directors is distributed to all staff and also posted on the Living Skills in the Schools website: livingskillsintheschools.org.

1. Compliance Officer

The Chief Executive Officer of the Living Skills in the Schools acts as the Compliance Officer for Living Skills in the Schools and is responsible for investigating and resolving all reported complaints and allegations concerning violations at his/her discretion and shall advise the CRC Board Treasurer. The Chief Executive Officer of the Living Skills in the Schools has direct access to the CRC Board Treasurer and is required to report to CRC Board Treasurer at least annually on compliance activity.

1. Accounting and Auditing Matters

The Treasurer of the CRC Board of Directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls, or auditing. The Treasurer of the CRC Board of Directors shall immediately notify the CRC Board of Directors of any such complaint and work with the CRC Board of Directors until the matter is resolved.

1. Acting in Good Faith

Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the local, state or federal law. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense, including but not limited to termination for employees (LSIS) or removal from the CRC Board in the case of members of the CRC Board of Directors.

VII.      Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

VIII.     Handling of Reported Violations

The Chief Executive Officer of the Living Skills in the Schools or the President of the CRC Board (or, in the event that the President is the subject of the complaint, then the Vice President of the CRC Board of Directors) will notify the sender and acknowledge receipt of the reported violation or suspected violation within five (5) business days. All reports will be promptly investigated and appropriate corrective action will be taken within thirty (30) days if warranted by the investigation.