In keeping with the policy of maintaining the highest standards of conduct and ethics, Procept will investigate complaints of suspected wrongdoing occurring within its programs and services; fraudulent or dishonest use or misuse of its resources or property; violations of policy; and violations of local, provincial, and federal law (each, “Suspected Wrongdoing”). Employees, contractors, board members, volunteers, clients, and community members are strongly encouraged to report all suspected wrongdoing pursuant to the procedures set forth below.
This policy supplements, but does not replace, Procept’s Human Rights Policy, Diversity Policy, Drug and Alcohol Policy, Health and Safety Policy, and any other complaint resolution/grievance policy, and any procedures required by law or regulation.
A person reporting concerns under this policy must act in good faith and have reasonable grounds for believing that the information reported indicates that Suspected Wrongdoing has occurred. A person who makes an allegation maliciously or with good reason to believe that the allegation was false will be subject to disciplinary action, up to and including termination of employment.
A person’s concerns about Suspected Wrongdoing should be reported directly to Procept’s president (currently Kevin Aguanno).
Reports of Suspected Wrongdoing should contain the names of the individuals involved, dates, and a description of the actions believed to be Suspected Wrongdoing. At no time should an individual who has reported or is considering reporting Suspected Wrongdoing undertake an independent investigation into the matter to obtain additional information.
Procept encourages anyone reporting Suspected Wrongdoing to identify himself or herself when making a report to facilitate the investigation of the Suspected Wrongdoing; however, reports may be submitted anonymously by mailing a written statement to:
Procept Associates Ltd.
Attn: Kevin Aguanno
18 King Street East, Suite 1400
Toronto, Ontario, M5C 1C4
Reports of Suspected Wrongdoing will be kept confidential to the extent possible, but confidentiality cannot be guaranteed in light of the need to conduct an adequate investigation, to comply with all applicable laws, and to cooperate with law enforcement.
Reports of Suspected Wrongdoing will be promptly reviewed and analyzed by Procept’s president. Appropriate corrective action will be taken if warranted by the investigation, and findings may be communicated to the reporting person, to the extent reasonably possible and consistent with any privacy and confidentiality limitation. Investigations may be conducted by independent persons such as auditors and/or attorneys at the discretion of Procept’s management.
Upon receipt of a report, Procept’s president shall promptly notify the individual who reported the Suspected Wrongdoing (to the extent that the individual’s identity is disclosed or a return address is provided) that he/she has received the report and will investigate it.
No employee, contractor, board member, volunteer, client, or community member who in good faith reports Suspected Wrongdoing, or who cooperates in the investigation of Suspected Wrongdoing, shall suffer harassment, retaliation, or adverse employment or other consequences. Any such retaliation should be reported, and Procept will promptly investigate the report, consistent with the procedures contained in this policy.
Anyone within Procept who retaliates against another individual for reporting Suspected Wrongdoing or cooperating with an investigation of suspected wrongdoing is subject to discipline up to and including termination of employment.