WHISTLEBLOWER POLICY of the American Congress of Obstetricians and Gynecologists The American Congress of Obstetricians and Gynecologists (the Congress) 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 Congress Statement of Values. I. Reporting Violations The Congress encourages any of its Executive Board members, officers, volunteers and employees who believe that there has been a violation of the Congress 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 Congress Compliance Officer, the Vice President, 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 Congress Finance Committee. The Congress 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 Congress encourages prompt reporting so that the complaint can be investigated in a timely manner. II. Investigations All alleged violations of the Congress Statement of Values that are reported under this policy will be investigated by the Compliance Officer or outside legal counsel, assisted by such the Congress 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 the Congress 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 Congress 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 Congress will communicate its findings and intended actions, if any, to the complainant. Violations of the Congress Statement of Values by an employee will be viewed as a serious offense and the employee may be disciplined and possibly terminated. The Congress Executive Board will address violations by the Congress Executive Board member, officer or volunteer. III. Appeals Procedure Any Executive Board member, officer, volunteer or employee who is dissatisfied with the Congress’ response to a reported violation of the Statement of Values may submit the reasons for that dissatisfaction with the Congress’ response to the Treasurer of the Congress. The Treasurer shall review the allegations, consider the issues and reasons for dissatisfaction with the Congress’ 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 the Congress attention so that the Congress 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 Employee Complaint Procedures contained in the Employee Handbook or report the action to the Congress 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 by the Congress Executive Board February 2009

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