Reporting of a Violation of Code of Ethics and Policies

(IPLAC's "Whistleblower Policy")
(Enacted April 4, 2012)

Purpose
The purpose of this policy is to provide all IPLAC members and staff (collectively “IPLAC persons”) with guidelines for the reporting of unethical or illegal behavior by IPLAC persons or vendors.

Policy
IPLAC is committed to lawful and ethical behavior in all of its activities and requires IPLAC persons and vendors to conduct themselves in a manner that complies with all applicable laws and regulations.

At any time an IPLAC person has a concern regarding the propriety or legality of any action contemplated to be taken or that has been taken by IPLAC, an IPLAC person, or an IPLAC vendor or believes that an action needs to be taken for IPLAC to be in compliance with the law or appropriate ethical standards, the IPLAC person should promptly report the concern in writing to the IPLAC President, President-Elect, or Vice-President. The IPLAC Committee on Ethics and Grievances shall investigate all reports. If IPLAC leadership is unresponsive, if the complainant believes IPLAC leadership will be unresponsive, or if IPLAC officers are themselves the subject of the concern, the IPLAC person may contact IPLAC’s Immediate Past-President to report his or her concern.

It is not necessary that an IPLAC person give his or her name or position in any notification. Whether or not the IPLAC person identifies himself or herself, the IPLAC person should report as much information as possible so that a proper investigation may be conducted. Every effort will be made to investigate a report by an IPLAC person as discreetly as possible. Because of the need to investigate the report, correct a problem, or prevent future problems, IPLAC cannot, however, promise complete confidentiality.

No negative or adverse action will be taken against an IPLAC person for reporting in good faith what he or she perceives to be wrongdoing, violations of law, or unethical conduct even if the report is mistaken. No negative or adverse action will be taken against an IPLAC person, IPLAC’s independent public accountants, or IPLAC’s legal counsel who assists in the investigation of a reported violation. Retaliation in any form will not be tolerated. Any act of alleged retaliation should be reported immediately and will be promptly investigated. A Board member who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including removal from the Board and suspension of membership.

Adopted by the Board of Managers April 4, 2012.