Tech Valley Center of Gravity (TVCOG) requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Volunteer leaders and employees of TVCOG must practice honesty and integrity in fulfilling responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility
This Whistleblower Policy is intended to encourage and enable volunteers, employees and others to raise serious concerns internally so TVCOG can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees and volunteers to report concerns about violations of TVCOG’s policies or suspected violations of law or regulations that govern TVCOG’s operations.

No Retaliation
It is contrary to the values of TVCOG for anyone to retaliate against any board member, officer, employee or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of TVCOG. An employee or volunteer who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

Reporting Procedure
TVCOG has an open door policy and suggests that employees and volunteers share their questions, concerns, suggestions or complaints with their supervisor, zone coordinator, work group leader or a member of the leadership team. 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 TVCOG’s Vice President, who serves as the organization’s compliance officer. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the Vice President, who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor, the executive director or the Vice President.

Vice President as Compliance Officer
TVCOG’s Vice President serves as its compliance officer and is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Vice President will advise the executive director and/or board of all complaints and their resolution and will report at least annually to the board on compliance activity relating to accounting or alleged financial improprieties.

Accounting and Auditing Matters
NYSNLA’s Secretary shall immediately notify the board of any concerns or complaint regarding corporate accounting practices, internal controls or auditing and work with the board until the matter is resolved

Acting in Good Faith
Anyone filing a written 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. 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.

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

Handling of Reported Violations
TVCOG’s Vice President will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.