What is our Disclosure of Wrongdoing policy?

Our Disclosure of Wrongdoing policy is intended to:
  • Facilitate the disclosure and investigation of significant and serious matters in or relating to Power To Be Adventure Therapy Society (hereinafter Power To Be) that a director, officer, volunteer, employee or stakeholder believes may be unlawful, dangerous to the public or injurious to the public interest;
  • Protect persons who make those disclosures;
  • Manage, investigate and make recommendations respecting disclosures of wrongdoings and reprisals; and
  • Promote public confidence in the administration of Power to Be Adventure Therapy.

What is wrongdoing?

Wrongdoing is:
  • An act or omission that creates: (i) a substantial and specific danger to the life, health or safety of individuals other than an act or omission that is to be corrected as a standard part of Power To Be’s adventure therapy programs’ policies and procedures, or (ii) a substantial and specific danger to the environment;
  • Mismanagement of Power To Be funds or its assets; and
  • Knowingly directing or counseling an individual to commit a wrongdoing mentioned above.

This policy does not include matters which are more appropriately defined as employment grievances or performance management issues.

Incidents of wrongdoing can be reported in writing in confidence to the Chair of the Risk Management Committee of the Power To Be Board of Directors as the ‘Designated Officer’.

Power To Be believes in the value of responsible, sound governance and operational practices, and supports that belief through policy and action.  Along with other governance and operational management innovations, the Policy for Disclosure for Wrongdoing will assist the organization to continue to demonstrate due diligence in its management and operations.

Responsibility to Report a Wrongdoing

It is the responsibility of all directors, officers, volunteers and employees to comply with this Policy if they are a witness to a wrongdoing.

Acting in Good Faith

Anyone reporting a wrongdoing must be acting in good faith and have reasonable grounds before reporting such.  Any report that proves to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Protection from Reprisal

No director, officer, volunteer or employee who in good faith reports a wrongdoing shall suffer harassment, retaliation or adverse employment or volunteer consequence.  A report may be made to the Designated Officer if a reprisal has been taken or directed against a witness.  Anyone who retaliates against someone who has reported a wrongdoing in good faith is subject to discipline up to and including termination of employment or volunteer position.  This Policy is intended to encourage and enable employees and others to raise serious concerns of wrongdoing within Power To Be prior to seeking resolution outside the organization.

Confidentiality

Written reports of wrongdoing may be submitted on a confidential basis by the witness or may be submitted anonymously.  Reports of wrongdoing will be kept confidential to the extent possible, consistent with the need to conduct an unbiased investigation and to mitigate the impact on the workplace through the investigation process.

Confidentiality will be maintained at all stages of disclosure and investigation to protect all parties involved in the process until corrective action is taken if necessary.  This is essential to ensuring an effective investigation and maintains the confidence of employees, volunteers and stakeholders.

Handling of Financial or Operational Complaints or Concerns

The Designated Officer will acknowledge receipt of a report of wrongdoing if a name is provided.  If a name is provided the witness will be advised by the Designated Officer within 10 days of planned follow-up action.  All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

All reported incidents will be documented and logged.  All files regarding disclosures of wrongdoing should be marked as investigation files and kept separate from existing files.  Access should be restricted to the Board of Directors and only those employees with a need to know.

Treatment of Reports of Wrongdoing

Reports of wrongdoing will be reviewed as soon as possible by the Chair of the Risk Management Committee with the assistance of the Director of Finance and Operations.  The Chair may utilize the assistance and direction of the Risk Management Committee and whomever it thinks appropriate.  To avoid conflicts of interest this Policy generally excludes supervisors, line managers and senior managers, other than the Director of Finance and Operations, from the assessment and investigation of any disclosure.  Appropriate investigation will occur dependent on the severity of the incident reported.

The principles of natural justice and procedural fairness apply to investigations into disclosures of wrongdoing.  Thus, the person who is the subject of the disclosure is entitled to know at the assessment phase of an investigation the allegations made against them, and given the right to respond and put forward further material that may inform the outcome of the investigation.  Knowing the identity of the person who made the allegation is not a part of natural justice, and should not be shared.

Each incident will be assessed according to its validity, significance and risk to the organization, and ability to be proven.  Following an investigation, the report of the Designated Officer will include whether the disclosure was substantiated and, where appropriate, a recommendation for corrective action will be made.  The results will be communicated to the witness, if a name was provided, and to the Board of Directors.  If a disclosure of wrongdoing was not substantiated some recommendations for corrective actions such as improvements to the internal operations or disciplinary action may still be required.

How Disclosures are Made

Disclosure must be in writing, addressed to the Designated Officer for investigating wrongdoing under this policy.

If a witness wishes to remain anonymous, they should not include their relationship to persons identified in their report, or their location relative to persons or incidents in their report.  Should a witness not wish to provide their name, reported incidents will still be accepted and investigated, as appropriate.

All disclosures will be treated in a confidential and sensitive manner.  The process is expected to protect the identity of a witness when communicating the disclosure report and throughout the investigative process.

Disclosure must include the following information:

  1. Details with respect to the location of the incident.
    • For example: Region, specific location, and department.
  2. Details of the wrongdoing that has been witnessed.
    • Include sufficient information for an independent person to understand the concern and to take action to investigate the wrongdoing.
  3. The full names and titles of individuals who are suspected of wrongdoing.
  4. When and how many times has an incident taken place?
  5. Name and contact information of the witness, if willing.
  6. If witness is willing for a meeting/telephone call with an Investigating Officer to discuss this matter?

Disclosures can be made via email to disclosure@powertobe.ca or via mail to Power To Be, 1017 Fort Street, Victoria, B.C., V8V 3K5.