WHISTLEBLOWER POLICY The American College of Obstetricians and Gynecologists (the College) requires that its Executive Board members, officers, volunteers and employees conduct their duties and responsibilities in accordance with high ethical standards and in compliance with the College Statement of Values. I. Reporting Violations The College encourages any of its Executive Board members, officers, volunteers and employees who believe that there has been a violation of the College Statement of Values to report any such incident regardless of the identity of the individual involved. An Executive Board member, officer, volunteer or employee who believes that there has been a violation of the Statement of Values should report the incident to the College Compliance Officer, the Vice President of Legal Affairs. If the Compliance Officer is believed to be involved in the conduct or if, for some other reason, the Executive Board member, officer, volunteer, or employee feels uncomfortable reporting the incident to the Compliance Officer, the individual should report the incident to the Chair of the College Finance Committee. College employees may also report violations to their supervisors or to the Director of Human Resources. Supervisors and the Director of Human Resources are required to report suspected violations to the Compliance Officer or, if the Compliance Officer is believed to be involved in the conduct, to the Chair of the Finance Committee. Suspected violations may be submitted anonymously. The College encourages prompt reporting so that the complaint can be investigated in a timely manner. II. Investigations All alleged violations of the College Statement of Values that are reported under this policy will be investigated by the Compliance Officer or outside legal counsel, assisted by such College Executive Board members, officers, volunteers or employees as they deem appropriate. Investigations will be conducted in as prompt and as confidential a manner as practicable and appropriate under the circumstances. All Executive Board members, officers, volunteers and employees have a duty to cooperate in College investigation of alleged violations of the Statement of Values and are required to preserve the confidentiality of the investigation. Upon receiving a report, the Compliance Officer or outside legal counsel will notify the College Audit Committee and will work with the Audit Committee until the matter is resolved. Upon completion of the investigation, appropriate corrective action will be taken if warranted by the investigation. The College will communicate its findings and intended actions, if any, to the complainant. Violations of the College Statement of Values by an employee will be viewed as a serious offense and the employee may be disciplined and possibly terminated. The College Executive Board will address violations by a College Executive Board member, officer or volunteer. continued. . . 2 College Whistleblower Policy (continued) III. Appeals Procedure Any Executive Board member, officer, volunteer or employee who is dissatisfied with College response to a reported violation of the Statement of Values may submit the reasons for that dissatisfaction with College response to the Treasurer of the College. The Treasurer shall review the allegations, consider the issues and reasons for dissatisfaction with College action, conduct a discretionary interview with the Executive Vice President and report the findings to the Audit Committee. IV. Good Faith Required Anyone filing a complaint concerning a suspected violation of the Statement of Values must be acting in good faith and have reasonable grounds for believing that a violation of the statement occurred. Any allegations that prove to be unsubstantiated and that prove to have been made maliciously or with knowledge of their falsehood will be viewed as a serious disciplinary offense. V. Retaliation Prohibited It is essential that Executive Board members, officers, volunteers and employees bring matters related to the Statement of Values to College’s attention so that the College can ensure compliance with the statement. No Executive Board member, officer, volunteer or employee who in good faith complies with, or reports a suspected violation of, the Statement of Values shall suffer harassment, retaliation, adverse employment consequences, or other adverse actions because of such compliance or report. Any employee who believes that he or she has been subjected to an adverse action because of complying with the Statement of Values, or reporting a suspected violation of the statement, should follow the College Employee Complaint Procedures contained in the Employee Handbook or report the action to the College Audit Committee. Any Executive Board member, officer or volunteer who has been subjected to an adverse action because of complying with the Statement of Values, or reporting a suspected violation of the statement should report the action to the Executive Board by contacting the Vice President of Administration. The Executive Board shall investigate the matter and take action as warranted. Approved December 2004 12/31/09 COI/whistleblowerpolicyC3

American Congress of Obstetricians and Gynecologists
409 12th Street SW, Washington, DC  20024-2188 | Mailing Address: PO Box 70620, Washington, DC 20024-9998