Section: 4.02
Issued: 11.15.2011
Updated: 04.02.2024
Updated:02.21.2025
Purpose:
The purpose of this policy is to delineate the responsibilities regarding reporting possible compliance violations, whistleblower protections and non-intimidation/ non-retaliation requirements.
Policy:
It is AHRC NYC Policy, as expressed in Section 4.01: Corporate Compliance Policy, that any employee, contracted employee, intern, volunteer, or agent who witnesses, learns of, or is asked to participate in potentially non-compliant activities must report the matter immediately to their supervisor or manager or to the Chief Compliance Officer/VP Corporate Compliance.
The Corporate Compliance Policy also requires that any AHRC NYC Supervisor, Manager, Officer, Director who receives information about possibly non-compliant activity must document the matter and report it to the Chief Compliance Officer/VP Corporate Compliance. If the potential non-compliant activity involves the Chief Corporate Compliance Officer/VP Corporate Compliance, the information must be reported without delay to the Chief Executive Officer.
Questionable activity should be reported to the Chief Compliance Officer/VP Corporate Compliance by calling the main switchboard and asking for the Chief Compliance Officer/VP Corporate Compliance:
AHRC NYC Main Switchboard: 212-780-2500
Anyone can make an anonymous call to the special Compliance Hotline: 212-780-4485.
Anyone can also make an anonymous report of a compliance violation via a link on the AHRC NYC website.
Upon receiving a compliance related complaint, the Chief Compliance Officer/VP Corporate Compliance will immediately begin an investigation, while appropriately documenting both the complaint and the investigation.
As appropriate, the Chief Compliance Officer/VP Corporate Compliance will keep the CEO and appropriate executive staff informed about the progress of the investigation.
Whistleblower Protections, Non-Intimidation and Non-Retaliation Policy
The False Claims Act provides protections for “whistleblowers” (persons who bring alleged wrongdoing to the attention of management or to outside authorities). Under the False Claims Act, whistleblowers can share in the recovery of monies paid fraudulently to organizations. No director, officer, employee, contractor, intern, or volunteer of AHRC NYC or its affiliates who, in good faith report any action or suspected action taken by or within these entities that is illegal, fraudulent or in violation of any adopted policy will suffer intimidation or other retaliation or, in the case of employees, adverse employment consequences.