Whistleblower Protection Procedure

Version: 0001
Effective Date: 7/1/2024

Objective #

This procedure establishes steps for a whistleblower retaliation complaint and outlines the responsive actions to be taken for investigating and resolution to full policy compliance.

Scope #

This policy applies to all UTFI employees, including full-time staff, part-time staff, student workers, student interns, and temporary staff for the organization.

Roles #

The UTFI Office of Talent Management (TM) will assist employees with the Whistleblower Protection process. Appropriate leadership and other staff will be involved in the process as warranted.

Procedure #

Any current or former employee who believes they have been subjected to an adverse personnel action or retaliation based on their prior disclosure of alleged wrongful conduct may protest the personnel action or retaliation by filing a written complaint document with the CEO.

The written whistleblower complaint filed must set forth in sufficient detail the necessary facts,
including:

1. Date(s) of the alleged adverse personnel action or retaliation.
2. Names of the UTFI employees involved in the alleged adverse personnel action or retaliation.
3. Nature of the alleged adverse personnel action or retaliation.
4. Facts supporting the alleged adverse personnel action or retaliatory act(s).
5. The effect on the complianant of the alleged adverse personnel action or retaliatory act(s).

The CEO or designee may require the complainant to provide such additional detail(s) as necessary in order to act on the complaint. If the complainant fails to provide the additional detail(s) requested within 15 business days, the complaint will be dismissed. At the discretion of the CEO or designee, this period may be extended if the complainant presents evidence of circumstances that made it difficult or impossible for the complainant to respond in the usual time period.

On receipt of a written whistleblower complaint, the CEO shall review the complaint and the CEO or designee will interview any individuals he or she deems appropriate and otherwise investigate the facts in order to expeditiously determine:

1. Whether the whistleblower complainant reported alleged wrongful conduct before the adverse action was imposed,
2. Whether the complainant suffered an adverse personnel action or other retaliatory act after reporting alleged wrongful conduct, and
3. Whether the adverse action or other retaliatory act resulted from the prior disclosure.

Within 30 business days after receipt of the complaint, the CEO shall notify the complainant in writing, with a copy to the employee’s supervisor, of the results of the review and whether the adverse personnel action or other retaliatory act is affirmed, reversed, or modified.

The supervisor will implement actions required by the decision, if any, and will verify implementation in writing to the CEO within 10 business days after receipt of the decision.

Definitions #

Retaliation: Retaliation is an adverse personnel action or other action to punish an employee who discloses alleged wrongful conduct.

Whistleblower: One who discloses alleged wrongful conduct.

Penalties/Disciplinary Action for Non-Compliance #

Violations of the procedure and any subsections herein may be cause for disciplinary action up to and including termination of employment.

Procedure Administration #

The table below identifies the responsible senior official, contact information and administrative responsibilities of policy/procedure matters.

Subject Matter	Office Name/Position Title	Email/Web Address
Authority	UTFI Senior Official of Talent Management	[email protected]
Point of Contact	UTFI Executive Director of Talent Management	[email protected]
Policy Location	Public Listing
Policy Review Schedule	Annual Review

History of Revision #

Related Policies/Guidance Documents #

Policy:

TM0017 Whistleblower Protection Policy